Lapsed LEI: What It Means and How to Renew

A lapsed LEI is an existing, valid Legal Entity Identifier whose annual renewal is overdue. Renewing re-validates its reference data: renew the existing LEI registration rather than submitting a new application. Whether LAPSED affects a particular activity depends on the rule that applies to the entity and its role.

Key points

• LAPSED describes the status of an LEI registration, not the disappearance of the code.
• An executing investment firm must keep its own LEI duly renewed for transaction reporting under EU MiFIR. That is different from the firm’s obligation concerning a client’s LEI.
• Issuers should keep their LEIs renewed. A separate DORA register rule calls for a valid and active LEI or an EUID for an ICT third-party provider that is a legal person.
• Check the registration status and renewal date, then renew the existing LEI if its reference data needs re-validation.

What a lapsed LEI means in GLEIF data

The GLEIF LEI-CDF 3.1 format defines LAPSED as an LEI registration that has not been renewed by its NextRenewalDate and is not known from public sources to have ceased operation. It is a registration status, not a statement that the legal entity has ceased to exist.

Renewal means checking the LEI reference data again against a third-party source. According to GLEIF’s explanation of timely LEI renewal, an LEI moves to LAPSED when the entity has not renewed by its Next Renewal Date or within the grace period set by its LEI issuer. GLEIF also states that a lapsed LEI remains valid: the status shows that renewal is behind schedule.

This distinction matters if someone describes the LEI as expired. The code still identifies the entity, but the reference data has not received its scheduled re-validation. Renewing the registration addresses that overdue check; applying for a different code is not the remedy described here.

What can a lapsed LEI affect?

There is no single answer for every entity or use of an LEI. The relevant obligation may concern the executing firm’s own LEI, a client’s identification, an issuer’s reference data or an ICT provider entry in a register. The distinctions below should be read separately rather than treated as a general ban on using a lapsed code.

Entity or role	What the source says	Practical distinction
Executing investment firm under EU MiFIR	Commission Delegated Regulation (EU) 2017/590 (RTS 22), Article 5, requires a firm executing a transaction to be identified in its transaction report by a validated, issued and duly renewed ISO 17442 LEI. It must keep its own LEI reference data renewed.	The firm’s own renewal is expressly required; it should address a LAPSED status.
Client or counterparty of an executing investment firm	Article 13(2) and (3) of the same regulation requires the firm to obtain the LEI of an eligible client before providing a service that triggers a transaction report, then check that the code meets ISO 17442, appears in the global LEI database and pertains to that client. ESMA’s transaction-reporting guidelines, section 5.5, say there is no requirement under Article 13(3) to ensure a client’s or counterparty’s LEI has been renewed.	Do not treat a client’s LAPSED status alone as an EU MiFIR rule that prohibits trading.
Issuer	ESMA’s Q&A on MiFIR data reporting, issuer LEI Q4, says issuers should ensure their LEI is renewed. Trading venues and systematic internalisers are not expected to ensure that the issuer’s LEI has been renewed.	The issuer should maintain its LEI; ESMA does not assign that renewal check to the venue or systematic internaliser.
ICT third-party provider that is a legal person	Implementing Regulation (EU) 2024/2956 (DORA register of information), Article 3(5), requires financial entities to identify these providers with a valid and active LEI or an EUID.	A lapsed status needs attention where the LEI is used to meet the valid-and-active requirement; the provision also allows an EUID.

These sources describe different responsibilities. In particular, ESMA’s position on a client’s renewal under Article 13(3) does not relax the executing firm’s obligation to renew its own LEI. If a specific reporting or register entry is in question, check the applicable requirements with your regulator or adviser.

How many LEIs are lapsed?

On 19 October 2026, the GLEIF LEI statistics (counts read from GLEIF data) showed 1,212,222 records with registration status LAPSED worldwide, compared with 1,988,227 with status ISSUED. That is more than 1.2 million lapsed records, but it is a dated snapshot, not a permanent count. Re-check the live GLEIF figures before citing them for a later date.

The count also should not be read as the number of entities barred from a particular activity. A registration status tells you whether renewal is current; the consequences depend on the rule and the entity’s role described above.

How to check and renew a lapsed LEI

1. Find the existing record. Check the LEI in the global LEI data and confirm that it pertains to the entity. Review its registration status and Next Renewal Date rather than assuming that a request to renew calls for a new code.
2. Check whether renewal is overdue. If the status is LAPSED, review the entity’s reference data for changes. The purpose of renewal is to have that data re-validated against a third-party source.
3. Renew the existing LEI. Provide updated information for verification through an LEI renewal process. The FCA’s guidance on UK MiFIR LEIs explains that the holder gives updated information to the Local Operating Unit so it can verify the data, and that the LOU may charge an annual renewal fee. You can renew an LEI without requesting a replacement code.
4. Check the record afterward. Confirm the published status and reference data, particularly if the LEI is needed for a transaction report or a register entry with a specific status requirement.

If an entity does not yet have an LEI, that is a different task from renewing a lapsed one. It can apply for an LEI; an entity that already has a lapsed LEI should work from its existing registration instead.

How to avoid another lapse

Keep track of the Next Renewal Date and arrange to review the entity’s reference data before it arrives. GLEIF’s account of lapsing refers to a grace period set by the LEI issuer, so do not assume that the same period applies to every registration. A reminder should allow time to confirm the data and submit any updated information.

Set a reminder well before the Next Renewal Date and check the reference data then. For broader context on LEI requirements, consult the LEIFast blog and regulation updates; for the immediate task, check your existing LEI’s status and Next Renewal Date, then renew it if overdue.