There are certain fields within EMIR, MiFIR and SFTR which require populating with an LEI or specifically ‘ISO 17442 Legal Entity Identifier (LEI) 20 alphanumerical character code’.
All LEIs for these reporting regimes must be valid and included in the GLEIF database.
As a general overview:
- for new transactions, LEIs for the executing party cannot be lapsed, and must have a status as per GLEIF as “Issued”, “Pending transfer” or “Pending archival”;
- for the other counterparty within a trade, their LEI is able to be “Lapsed” with GLEIF; and
- the Initial Registration Date of an LEI must be equal to or after the trade date.
Below are the three regimes and the primary fields which require LEIs to be populated. For each field, details are provided alongside as to whether the entered LEI can be lapsed or not in submission.
The regimes differ in terms of specific validation rules and action types, even though field names may be similar in some cases.
| Field | Use | LEI Validity Rule |
| Reporting Firm ID | For Action Types “N”, “M”, “R”, “Z”, “V”, “P”: LEI with status “Issued”, “Pending transfer” or “Pending Archival” only. | For Action Type “E”, LEI can be any status. |
| Submitting Entity ID | LEI status of “Issued”, “Pending Transfer” or “Pending Archival”. | LEI cannot be lapsed in order to submit. |
| Other Counterparty ID | For Action Types “N”, “M”, “R”, “Z”, “V”, “P”: LEI with status “Issued”, “Lapsed”, “Pending transfer” or “Pending archival” only. | LEI is able to be lapsed. |
| Beneficiary ID | For Action Types “N”, “M”, “R”, “Z”, “V”, “P”: LEI with status “Issued”, “Pending transfer”, “Lapsed’ or “Pending Archival” only. For Action Type “C’: LEI with status “Issued”, “Pending transfer”, “Pending Archival”, “Lapsed” or “Retired” only. For Action Type “E”, LEI can be any status. | LEI cannot be lapsed in order to submit, except for Action Type “C” or “E”. |
| Executing Entity ID | The status of the LEI must be “Issued”, “Pending transfer” or “Pending archival”. | LEI cannot be lapsed in order to submit. |
| Submitting Entity ID | LEI of Submitting Entity ID must have a status of “Issued”, “Lapsed”, “Pending Transfer” or “Pending Archival”. | LEI is able to be lapsed. |
| Buyer/Seller IDs | The status of the LEI must be “Issued”, “Lapsed”, “Pending transfer” or “Pending archival”. | LEI is able to be lapsed. |
| Buyer/Seller Decision Maker IDs | The status of the LEI must be “Issued”, “Lapsed”, “Pending transfer” or “Pending archival”. | LEI is able to be lapsed. |
| Field | Use | LEI Validity Rule |
| Report submitting entity | For action types “NEWT”, “MODI”, “VALU”, “COLU”, “ETRM”, “CORR”, or “POSC”: status of the LEI must be “Issued”, “Pending transfer” or “Pending Archival”. For action type “EROR”, LEI can be any status. | LEI cannot be lapsed in order to submit, except for action type “EROR”. |
| Reporting counterparty | For action types “NEWT”, “MODI”, “VALU”, “COLU”, “ETRM”, “CORR”, or “POSC”: status of the LEI must be “Issued”, “Pending transfer” or “Pending Archival”. For action type “ETRM”, LEI can also be “Lapsed” or “Retired”. For action type “EROR”, LEI can be any status. | LEI cannot be lapsed in order to submit, except for action type “EROR” or “ETRM”. |
| Entity responsible for the report | The status of the LEI shall be “Issued”, “Pending transfer” or “Pending archival”. For action type “ETRM”, LEI can also be “Lapsed” or “Retired”. | LEI cannot be lapsed in order to submit, except for action type “ETRM”. |
| Other Counterparty | For action types “NEWT”, “MODI”, “VALU”, “COLU”, “ETRM”, “CORR”, or “POSC”: status of the LEI must be “Issued”, “Lapsed”, “Pending transfer” or “Pending Archival”. For action type “ETRM”, LEI can be “Retired”. For action type “EROR”, LEI can be any status. | LEI is able to be lapsed. |
