Who Needs an LEI? A Practical Checklist for Legal Entities

Who needs an LEI depends on what a legal entity does, not simply on whether it is a company. An LEI is needed before certain reportable investment trades, is used in derivatives and securities financing reporting, and may be required to identify an ICT supplier under DORA. Other rules use an LEI only where one is available and do not, by themselves, require a company to obtain one.

Key points: who needs an LEI?

• Trading: A bank or broker must obtain an eligible legal-entity client’s LEI before providing a service that triggers an EU transaction report.
• Derivatives and securities financing: Reporting rules use LEIs to identify legal entities involved in these transactions.
• DORA suppliers: The identification rule differs according to whether the ICT provider is established inside or outside the Union.
• Payments and future customer checks: An LEI used where available is not the same as a general duty to obtain one.

An LEI is a unique 20-character alphanumeric code based on ISO 17442. Each code represents one entity and links to reference data from authoritative local sources; the data is free to access through GLEIF – The Legal Entity Identifier (LEI).

Checklist: when is an LEI mandatory?

The relevant question is which activity or reporting rule applies. The table separates a pre-trade requirement from rules governing reports or supplier identification; they should not be treated as one universal LEI requirement.

Situation	Rule	Who requests or uses the LEI
A company buys or sells reportable shares, bonds, ETFs or other financial instruments through a bank or broker.	MiFIR transaction reporting and RTS 22 require an eligible legal-entity client’s LEI before the firm provides a service triggering a transaction report.	The investment firm obtains and checks the client’s LEI.
A legal entity is involved in a reportable derivative contract, such as an FX forward or interest rate swap.	EMIR requires derivative reporting; its reporting rules identify legal-entity counterparties by LEI.	The LEI is used in the report, even if reporting is delegated.
Counterparties enter into reportable securities financing transactions.	SFTR requires reporting that includes global LEIs.	The LEIs are used in trade repository reporting.
A legal-person ICT provider supplies a financial entity.	DORA register rules allow an LEI or EUID for a provider established in the Union; only an LEI may be used for one established outside the Union.	The financial entity identifies its provider in its register.

Trading through a bank or broker

Regulation (EU) No 600/2014 (MiFIR), Article 26(6) requires investment firms to use an LEI to identify clients that are legal persons in transaction reports to the competent authority. Commission Delegated Regulation (EU) 2017/590 (RTS 22), Article 13(2) says a firm must obtain the LEI from an eligible client before providing a service that triggers that reporting obligation. Article 13(3) requires the firm to check that the code complies with ISO 17442, appears in the Global LEI database and pertains to the client.

For a company planning a reportable trade, this is the practical meaning of “no LEI, no trade”: give the bank or broker the entity’s LEI before the service is provided. Whether a particular transaction triggers reporting depends on its details; check with the investment firm or an adviser if the position is unclear.

Derivatives, securities financing and ICT suppliers

Regulation (EU) No 648/2012 (EMIR), Article 9(1) requires counterparties and CCPs to ensure that derivative contracts, and their modifications or terminations, are reported to a trade repository no later than the following working day. This covers financial and non-financial counterparties, including a company using an FX forward or interest rate swap with its bank; reporting may be delegated. Commission Implementing Regulation (EU) 2022/1860 (EMIR reporting), Article 3(1) requires an ISO 17442 LEI to identify a counterparty that is a legal entity, among other reported parties. Article 3(2) also addresses renewal of the reference data of the LEI for counterparty 1 and the entity responsible for reporting.

Regulation (EU) 2015/2365 (SFTR), Article 4 covers reporting for securities financing transactions, including repos, securities or commodities lending, buy-sell backs and margin lending. Counterparties report by the next working day, and the reporting format includes global LEIs.

Under Commission Implementing Regulation (EU) 2024/2956 (DORA register of information), Article 3(5), financial entities identify ICT third-party service providers that are legal persons by a valid and active LEI or an EUID, and by both where available. Only an LEI may be used for a legal person established outside the Union. DORA has applied since 17 January 2025. An IT or software provider asked for an LEI by a financial-entity client should confirm which identifier the client needs; the DORA ICT supplier LEI guide explains this distinction.

Where an LEI is used only if available

Not every rule that mentions an LEI creates a duty to get one. Under Regulation (EU) 2023/1113 (transfers of funds and crypto-assets), Article 4, a funds-transfer message carries the current LEI of the payer and payee where it exists, or an available equivalent official identifier in its absence. That provision does not oblige a company to obtain an LEI.

Regulation (EU) 2024/886 (instant payments), Article 5c(1)(b) allows a payer’s bank to offer verification of a legal-person payee using its IBAN with an identifier such as an LEI, EUID or fiscal number. This is an option for verification, not a duty for the payee to hold an LEI.

Regulation (EU) 2024/1624 (AMLR), Article 22(1) is adopted but, as of 10 November 2026, not yet applicable. It will apply from 10 July 2027 and provides for obliged entities to collect a legal-entity customer’s LEI “where available”. It does not require that customer to obtain one.

Who usually does not need one?

There is no requirement in the rules above for every company to hold an LEI. A legal entity that does not enter the covered activities or supplier arrangements should not assume it needs one merely because LEIs appear in payment or future customer-information rules. Equally, a counterparty may request an LEI for a particular arrangement; ask which requirement or reporting process the request relates to rather than assuming it applies to every activity.

How to check, obtain and maintain an LEI

1. Search before ordering. Use the free GLEIF LEI Search to find the entity’s record and check whether its status is ISSUED or LAPSED. The LEI lookup and record-status guide explains what to check in a result.
2. Identify the relevant activity. Confirm whether the request concerns a reportable investment trade, a derivative or securities financing report, or DORA supplier identification. If the answer depends on transaction or entity details, check with the bank, broker, regulator or an adviser.
3. Obtain an LEI if needed. GLEIF – Get an LEI: find LEI issuing organizations says entities can use any issuer accredited for their jurisdiction; they are not limited to an issuer in their own country.
4. Check the record when reporting continues. In particular, EMIR reporting rules require counterparty 1 and the entity responsible for reporting to ensure their LEI reference data is renewed in accordance with the accredited issuer’s terms when reporting.

Cost and the next step

No single price follows from the legal requirements: check the applicable service terms before ordering. LEIFast lists its charges on its pricing page. For an existing LEI, see the LEI transfer page. If the GLEIF search shows that the entity has no LEI and its activity requires one, confirm the requirement with the requesting party, then use the LEIFast order form to apply for an LEI before the reportable trade or other process that calls for it.