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The LEI code, or Legal Entity Identifier, is the global standard for identifying financial market participants. It is required for trading, regulatory reporting, and KYC compliance across 200+ jurisdictions.
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LEI registration for companies and funds in the EU
More EU rules depend on the LEI code than in any other market. Under MiFID II and MiFIR, investment firms must have their client's LEI code before they execute a transaction in a reportable instrument. Under EMIR, both counterparties to a derivative are reported by LEI code. Since the EMIR Refit changes, trade repositories also reject reports when the reporting counterparty's LEI code is not kept up to date. DORA added another use: financial entities list their ICT third-party providers by LEI code in their register of information, so technology and outsourcing suppliers to banks and insurers are now being asked for one too. Issuers filing ESEF annual reports tag them with their LEI code.
For an Irish company we verify the application against the Companies Registration Office (CRO) record: company number, legal name, registered office and status. Maltese entities are checked against the Malta Business Registry, and companies elsewhere in the EU against their national business register. The applicant must be a director, company secretary or someone they have authorised.
Investment funds, including ICAVs, sub-funds and UCITS umbrella structures, each get their own LEI code. The fund manager or administrator normally applies on their behalf and records the fund relationships in the same application.
What to have to hand
- Register number: CRO number for Ireland, MBR registration number (e.g. C 12345) for Malta, or your national register ID
- Registered office exactly as filed with the register
- Name and role of the applicant, and an authorisation letter if they are not a director
- Direct and ultimate parent details, if the entity is part of a consolidated group
- For funds: the fund manager's LEI code and the umbrella or master fund relationship
EU LEI registration questions
We are an IT supplier to a bank. Why are we being asked for an LEI code?
Under DORA, banks, insurers and investment firms keep a register of information on their ICT third-party providers, and the LEI code is the identifier used for providers that are legal entities. Your client needs your LEI code to complete that register.
Does an Irish ICAV need one LEI code or one per sub-fund?
Each sub-fund that trades or is reported separately needs its own LEI code, as well as the umbrella ICAV. The fund administrator usually registers them together.
Can a company in one EU country get an LEI code from a provider in another?
Yes. LEI codes work across borders. An LEI code issued by any GLEIF-accredited issuer is accepted by every EU regulator and trade repository.
Is an LEI code needed for CSRD or ESEF reporting?
Issuers listed on an EU regulated market include their LEI code in their ESEF annual financial report. Sustainability reporting under CSRD is published inside the same management report, so a listed issuer will already have one.
Our company has just been incorporated. Can we apply straight away?
Yes, as soon as the company appears on the national register. If the registry has not published the record yet, include the certificate of incorporation with the application.