LEI Hong Kong: Why Is Your Bank Asking for One?

If your bank asks for an LEI in Hong Kong, the request may relate to its OTC derivatives reporting obligations. Reporting entities must use LEIs for parties on their own side of a transaction and are expected to request them from clients, although a client counterparty on the other side is not legally required by this rule to have one.

What this means in Hong Kong

A Hong Kong private limited company hedging USD/HKD with an FX forward through its bank may be asked to provide its Legal Entity Identifier (LEI) for the bank’s transaction report. The same question may arise for a trading company in Kwun Tong entering an interest rate swap on a HKD loan. The request reflects a distinction in the reporting instructions: an LEI is mandatory for parties on the reporting entity’s side, while an LEI is the preferred identifier for a counterparty on the other side.

The applicable source is the HKMA/SFC Supplementary Reporting Instructions (SRI) for OTC derivative transactions, version 3.0. Its client-request process explains why a bank may ask for an LEI even where the client is not itself subject to the mandatory LEI requirement for the bank’s side of the trade.

Key points about LEI Hong Kong reporting

• The SRI version 3.0 took effect on 29 September 2025.
• Under paragraph 76, reporting entities must use LEIs issued under the Global LEI System for all parties on their own side of a transaction.
• Under paragraph 77, an LEI is first in the priority order for identifying Counterparty 2 and other parties, but alternatives are permitted.
• Under paragraph 78, reporting entities are expected to have a process to request LEIs from clients and to encourage or assist clients without one to obtain it.

The distinction matters when answering a bank’s request. A request for an LEI does not, by itself, mean that the client counterparty is legally required to obtain one under these reporting instructions. It does mean that the bank has a stated expectation to seek it, rather than moving directly to another identifier without considering an LEI.

What changed on 29 September 2025?

The SRI version 3.0 took effect on 29 September 2025. From that date, new transactions are reported in ISO 20022 XML format, according to the FAQs on the SF (OTC Derivative Transactions – Reporting and Record Keeping Obligations) Rules v2.0. The updated FAQ also addresses which LEI to report for a branch.

The date should not be mistaken for the start of Hong Kong OTC derivatives reporting or for the introduction of mandatory LEIs on a reporting entity’s side. Reporting began on 10 July 2015 and expanded to all specified OTC derivatives on 1 July 2017. The HKMA press release on the HKMA/SFC consultation conclusions of 27 June 2018 states that mandatory LEI use in trade reporting applies only to entities on a reporting entity’s side of a transaction, from 1 April 2019.

Who reports, and when might your bank ask?

The Reporting Rules FAQ identifies authorised institutions, including banks, approved money brokers, licensed corporations, recognised clearing houses and ATS-CCPs as entities subject to mandatory reporting. Reports are due within 2 business days, commonly described as T+2. These are reporting obligations for the specified entities; they do not make every corporate counterparty a reporting entity.

A bank may therefore ask for your company’s LEI while gathering the information it needs to report a transaction. If your company has an LEI, provide the identifier for the relevant legal entity so the bank can verify that it pertains to that entity and is in the Global LEI System. If the request concerns a particular entity or transaction whose treatment is unclear, check the details with the bank and your adviser or regulator.

For related background, see the Hong Kong LEI articles. The operative question for a client responding to its bank remains which legal entity is the counterparty and which identifier the bank needs for its report.

What happens if your company has no LEI?

Paragraph 77 of the SRI sets a priority order for Counterparty 2 and other parties. It permits the reporting entity to use another identifier where the counterparty does not have an LEI; the list is not a declaration that every client must first obtain an LEI. The alternatives must be considered in the stated order.

Priority	Identifier
1	LEI issued under the Global LEI System, ISO 17442
2	SWIFT BIC
3	Unique Business Identifier implemented by the Companies Registry
4	Certificate of Incorporation number for a local company, or Certificate of Registration number for a non-Hong Kong company
5	Business Registration Number issued by the Inland Revenue Department
6	User defined code

Tell the bank if your company does not have an LEI, rather than supplying an identifier for a different entity. The bank can then determine how to apply the reporting instructions to the transaction. Paragraph 78 expects reporting entities to explain the LEI to clients without one and encourage or assist them to obtain one.

Branches and keeping LEI information current

If a reporting entity or its counterparty is a branch, Reporting Rules FAQ Q60 says the reporting entity should report the head office LEI. A branch should therefore confirm with the bank which head office legal entity is involved, rather than assuming that a separate branch identifier is required.

Paragraph 79 of the SRI says reporting entities should take reasonable steps to verify that LEIs they obtain belong to the entities concerned and are in the Global LEI System. They are not expected to check a counterparty’s LEI registration status before each trade, but should have arrangements for the counterparty to tell them about changes in status. Reporting entities should also maintain and use current and valid LEIs for their own groups of companies.

If your company already has an LEI, check that the bank has the correct identifier and tell it about any change in status under its arrangements. If the LEI needs attention, you can renew an LEI. A counterparty should not infer from the absence of a check before each trade that its identifier information can be left unreviewed.

How to get an LEI in Hong Kong

Start by identifying the legal entity named in the bank’s request. For a Hong Kong company, its Companies Registry or business registration details can help identify the correct entity during the application process. The GLEIF Registration Authorities list identifies the Companies Registry and the Business Registration Office of the Inland Revenue Department as Hong Kong registration authorities. A registration authority is not necessarily the organisation that issues the LEI.

Next, use the GLEIF list of LEI issuing organisations to check which issuers are accredited to serve Hong Kong; an entity can choose among issuers serving its jurisdiction. You can then apply for an LEI for the correct legal entity and give the resulting identifier to your bank.

Before submitting the bank’s requested information, confirm whether the counterparty is the company itself or a branch and whether it already has a head office LEI. That establishes which entity and identifier the bank needs to assess under the SRI.