FDTA LEI: What the US Joint Rule Changes Now

Since 1 October 2026, the FDTA LEI joint rule has made ISO 17442, the Legal Entity Identifier (LEI), the joint legal entity identifier standard for nine US financial regulators. The rule does not, by itself, change any reporting requirement: an agency must act through its own rulemaking before its data standards affect reporting.

Background: the FDTA and the nine agencies

The Financial Data Transparency Act of 2022 (FDTA) provides for joint data standards and subsequent agency-specific rules. The final joint rule, Financial Data Transparency Act Joint Data Standards, published in the Federal Register, was issued by the OCC, the Federal Reserve Board, the FDIC, the NCUA, the CFPB, the FHFA, the CFTC, the SEC and the Department of the Treasury.

For a business that reports to one of these agencies, the distinction is between a standard the agencies have selected jointly and an instruction that applies to a particular report. Reporting entities should check whether the agency they report to has issued its FDTA rule and continue to follow the requirements that currently apply to their filings.

FDTA LEI: key points

• What is final: The joint rule took effect on 1 October 2026 and names ISO 17442 as the joint legal entity identifier standard.
• What has not changed: The joint rule alone changes no reporting requirement. The FDTA does not require an agency to collect or publish information it did not collect or publish before the FDTA.
• What comes next: Each implementing agency must adopt data standards by rule for certain information collections. Those standards must take effect not later than two years after the final joint rule is promulgated.
• What remains open: Agencies may tailor their standards and may use an identifier other than the LEI, instead of or in addition to it, in an agency-specific rulemaking.

These points set a boundary for planning. The joint rule identifies a common standard; it is not a substitute for checking the reporting instructions of the agency that receives your data.

What the joint rule establishes

Section 124(c)(1)(A) of the Financial Stability Act requires the joint standards to include a common, nonproprietary legal entity identifier available under an open license. The agencies selected ISO 17442 – Financial Services – Legal Entity Identifier (LEI). The standard is codified, for example, in 12 CFR 15.2 (eCFR) for the OCC.

The agencies describe the LEI as a global, 20-character alphanumeric standard that uniquely and unambiguously identifies a legal entity. They concluded that it meets the FDTA requirement for a common, nonproprietary identifier available under an open license. That conclusion explains the choice of joint standard.

The joint rule also establishes ISO 4914 UPI for swaps and security-based swaps, ISO 10962 CFI for other financial instruments, ISO 8601 for dates and ISO 4217 for currencies. The agencies did not establish the proposed FIGI standard. These selections describe the joint framework that agencies will consider when they make their own rules.

What the joint rule does not do

Federal Register 2026-12787 discusses the distinction between joint standards and subsequent agency-specific action. Nor does the FDTA require an agency to begin collecting or publishing information it did not already collect or publish before the Act.

The LEI’s place in the joint rule also does not settle how every agency will identify entities in every covered collection. Implementing agencies must incorporate the joint standards to the extent feasible, but they may tailor the standards they adopt or adopt standards not established in the joint rule. An agency-specific rulemaking could use an identifier outside the joint standards instead of, or alongside, the LEI.

Whether a later requirement affects a particular entity will depend on the relevant agency’s rule and the collection involved. If the application of an existing or future requirement is unclear, check with the responsible regulator or a qualified adviser rather than treating the joint rule as a filing instruction.

What comes next for agency-specific rules

Each implementing agency must adopt data standards by rule for certain collections of information. Those agency-specific standards must incorporate the joint standards to the extent feasible and must take effect not later than two years after the final joint rule is promulgated. As GLEIF’s LEI Lightbulb blog no. 22 explains, each implementing agency now has up to two years to complete its own rulemaking.

The agency-specific stage matters because it will determine how standards apply to particular reporting processes and whether an agency tailors them. Reporting teams should distinguish the final, effective joint rule from any later agency action and check whether the agency they report to has issued its FDTA rule.

For background as agency requirements develop, keep track of LEI regulation updates, but use the relevant agency’s own rules and reporting instructions to determine what a filing requires.

Who may be affected and what to do now

Entities that report information to the nine agencies may need to assess agency-specific data standards when those agencies adopt them. Scope and implementation will depend on the agency and the information collection.

1. Identify the relevant agency and reports. Note which of the named regulators receives information from your entity so that you can review the applicable instructions when they change.
2. Separate current duties from FDTA planning. Continue meeting existing reporting requirements.
3. Review later agency rules against your reporting process. Check which collections they cover, when their standards take effect and whether the agency uses the LEI or another identifier.
4. Check any LEI you already use. If a separate, existing requirement calls for an LEI, confirm that your records support that obligation. You can renew an LEI if renewal is needed for that existing use.

Entities that already need an LEI for an existing report, or want to be ready when their agency adopts its standards, can apply for an LEI. First confirm which entity must be identified and which reporting requirement applies.

FDTA rule timeline

Stage	Status as of 19 October 2026	Reporting effect
25 June 2026: joint rule published	Final rule published as 2026-12787, 91 FR 38246	Established the joint standards, including ISO 17442
1 October 2026: joint rule effective	In force	Agency-specific standards determine reporting application
Agency-specific rulemaking	Each agency’s own rulemaking	Standards must take effect not later than two years after the final joint rule is promulgated; their application depends on each agency’s rule

The next practical step is to check the instructions for the reports your entity files today, then assess any agency-specific FDTA rule when it is adopted.