Lapsed LEI in Canada: Renewal Rules and Next Steps

A lapsed LEI in Canada remains a valid Legal Entity Identifier, but its scheduled renewal and reference-data re-validation are overdue. Canadian derivatives reporting rules require certain local counterparties to maintain and renew their own LEIs. If yours is LAPSED, check the applicable rule and renew the existing registration rather than applying for a new code.

What this means in Canada

For Canadian derivatives reporting, the central question is whether the entity is a local counterparty to a reportable derivative and eligible to receive an LEI. The rules address entities other than individuals. An Ontario manufacturer hedging CAD/USD with an FX forward through its bank, for example, should check whether its transaction falls under the reporting rule rather than assume the bank handles the manufacturer’s LEI renewal.

In Ontario, OSC Rule 91-507 Trade Reporting, section 28.1, requires an eligible local counterparty to a derivative required to be reported under that rule, other than an individual, to obtain, maintain and renew an LEI assigned under Global LEI System standards. Outside Ontario, Québec and Manitoba, Multilateral Instrument 96-101 Derivatives: Trade Reporting (MI 96-101), section 28(2), requires an eligible local counterparty other than an individual to obtain an LEI before executing a transaction and maintain and renew it while it remains a counterparty to a reportable derivative.

Québec has AMF Regulation 91-507, section 28.1, and Manitoba has MSC Rule 91-507, section 28.1. The Canadian Securities Administrators (CSA) multilateral notice explains that amendments effective 25 July 2025 harmonized the maintenance and renewal provision across CSA jurisdictions; it does not mean the renewal duty first arose then.

The CSA’s reminder is direct: “We remind all local counterparties that they are not in compliance with securities laws if their own LEI is lapsed.” The CSA also says a reporting counterparty need not determine whether its counterparty’s LEI is active, meaning renewed each year. If an LEI is reported, however, it must be valid and correspond to that counterparty. Do not rely on a dealer’s reporting checks to meet your own renewal duty.

As of 20 October 2026, GLEIF LEI statistics showed 26,891 LEIs with a legal address in Canada marked LAPSED and 27,734 marked ISSUED. These are status counts, not a count of Canadian entities subject to a particular derivatives rule.

Key points for LEI renewal in Canada

• LAPSED describes an overdue registration renewal; GLEIF says the LEI remains valid.
• A Canadian local counterparty covered by the applicable derivatives reporting renewal rule must attend to its own LEI, even if a dealer reports the transaction.
• The CSA does not require a reporting counterparty to determine whether another counterparty’s LEI is active, but a reported LEI must be valid and match that counterparty.
• Renew the existing registration after reviewing the entity’s reference data.

What LAPSED means in GLEIF data

The GLEIF LEI-CDF 3.1 format defines LAPSED as a registration not renewed by its NextRenewalDate where the entity is not known from public sources to have ceased operation. The status does not, by itself, say the entity has stopped operating.

Renewal re-validates an LEI’s reference data against a third-party source. GLEIF’s explanation of timely LEI renewal says a registration becomes LAPSED if it is not renewed by its Next Renewal Date or within the grace period set by its LEI issuer. GLEIF also says the LEI remains valid; the status signals that renewal is behind schedule.

How Canadian obligations differ from other markets

A valid identifier and a current renewal status are different questions. The Canadian Securities Administrators’ statement about a local counterparty’s own lapsed LEI should not be replaced with guidance written for EU investment firms. The following examples concern other markets and do not establish Canadian requirements.

Other-market role	Source and distinction
Executing EU investment firm	Commission Delegated Regulation (EU) 2017/590 (RTS 22), Article 5, requires its transaction report to identify the firm by a validated, issued and duly renewed ISO 17442 LEI. The firm must keep its own reference data renewed.
Client of an executing EU investment firm	Article 13(2) and (3) of that regulation requires the firm to obtain an eligible client’s LEI before a service triggering a transaction report and check the code, its presence in the global LEI database and its connection to the client. ESMA’s transaction-reporting guidelines, section 5.5, say Article 13(3) does not require the firm to ensure the client’s or counterparty’s LEI has been renewed.
EU issuer	ESMA’s Q&A on MiFIR data reporting, issuer LEI Q4, says issuers should renew their LEIs, while trading venues and systematic internalisers are not expected to check issuer renewal.
ICT third-party provider under EU DORA register rules	Commission Implementing Regulation (EU) 2024/2956, Article 3(5), requires financial entities to identify a provider that is a legal person using a valid and active LEI or an EUID.

UK guidance is also market-specific: the Financial Conduct Authority’s guidance on UK MiFIR LEIs describes giving updated information to the Local Operating Unit for verification and notes that it may charge an annual renewal fee. Neither UK guidance nor the EU provisions above determines a Canadian entity’s obligations.

How to check and renew a lapsed LEI

1. Locate the existing record. Check that the LEI pertains to your entity, then review its registration status and Next Renewal Date.
2. Review the entity’s data. If the record says LAPSED, identify information that needs updating so the reference data can be re-validated.
3. Renew the registration. Use an LEI renewal process for the existing LEI; do not submit a new-code application to address a lapse.
4. Check the published record. Confirm the resulting status and reference data, especially if the LEI is used for a reportable derivative.

If the entity has no LEI, it can apply for an LEI instead. For other LEI topics, see the LEIFast Canada blog. If you already have an LEI, start by checking its status and Next Renewal Date, then renew the existing registration if overdue.