LEI Singapore: MAS Derivatives Reporting Rules

For MAS derivatives reporting, whether your business needs an LEI in Singapore depends on how it is identified in a reportable derivatives contract. A specified person is identified with an LEI, or a pre-LEI if an LEI is unavailable; other counterparties have further identifier options if they have neither. The revised reporting rules have applied since 21 October 2024.

What this means in Singapore

A Singapore company asked for an LEI by its bank should establish whether it is itself a specified person or is being identified as the bank’s counterparty. Those positions have different identifier rules. A Singapore Pte Ltd hedging USD/SGD through a bank should therefore ask which reporting field and counterparty category the request concerns, rather than assume every Singapore company needs an LEI.

The same distinction matters for a fund (VCC) whose manager trades interest rate swaps with a Singapore bank branch. The entity identified as counterparty, its status under the reporting rules and the branch rule all matter. If the fund’s reporting position is unclear, check it with the reporting entity or an adviser.

Key points on MAS derivatives reporting LEIs

• A specified person is identified with an LEI, or a pre-LEI if an LEI is unavailable.
• A counterparty that is not a specified person is identified with an LEI or pre-LEI if it has one; other identifiers are available if it has neither.
• A new counterparty LEI must be reflected in a reported trade while the position remains open.
• For reporting involving a branch, MAS directs the reporting entity to use the relevant head office LEI.

These are derivatives reporting rules, not a general LEI requirement for every company incorporated in Singapore. The identifier fields are set out in the MAS Guidelines to the SF(RDC)R (31 May 2024).

What changed on 21 October 2024?

The Securities and Futures (Reporting of Derivatives Contracts) (Amendment) Regulations 2024 (S 410/2024), published on 10 May 2024, amended the Securities and Futures (Reporting of Derivatives Contracts) Regulations 2013. The amendments adopted CPMI-IOSCO technical guidance on the unique transaction identifier, unique product identifier and critical data elements. The revised regulations commenced on 21 October 2024, when the MAS Guidelines to the SF(RDC)R took effect.

The transition included a re-reporting requirement for existing specified persons. Under paragraph 4.2 of the MAS Guidelines, they had to re-report outstanding specified derivatives contracts that had a remaining maturity of at least 6 months as at 21 October 2024 – those maturing on or after 21 April 2025 – by 21 April 2025. That deadline has passed; it was not a deadline for every Singapore entity to obtain an LEI.

For current reporting, the practical question is whether the LEI or other identifier in a report matches the applicable counterparty field rules. A company receiving an identifier request should ask the reporting entity whether the request concerns its own reporting obligation or its identification as a counterparty.

How are counterparties identified?

The MAS Guidelines distinguish specified persons from other counterparties in the reportable fields for Counterparty 1 and Counterparty 2. The table summarises the SF(RDC)R LEI field rules; it does not determine whether a particular entity is a specified person.

Party being identified	Identifier under the MAS Guidelines
Specified person	LEI, or pre-LEI if an LEI is unavailable.
Counterparty that is not a specified person	LEI or pre-LEI; if it has neither, SWIFT BIC, AVOX ID, an identifier issued by a licensed trade repository or licensed foreign trade repository, or a client code.
Individual	Client code.

A separate reportable field indicates whether an LEI, including a pre-LEI, was used for Counterparty 2. This means that supplying an identifier and recording which kind of identifier was used are distinct reporting tasks. If a bank asks your company for its LEI, confirm which legal entity it intends to identify and whether it already holds an identifier for that entity.

What if an LEI changes or a branch is involved?

An LEI change can affect trades already reported. In answer A4.2 of the MAS FAQs on the SF(RDC)R (30 October 2024), MAS says that when a counterparty has a new LEI, the change has to be reflected in the reported trade for as long as it remains an open position. A company should therefore tell the entity responsible for reporting about a new LEI and identify any open positions that may be affected.

Branches need a separate check. Under MAS FAQ A4.6, amended on 30 October 2024, a reporting entity that is a branch reports its head office LEI. When the counterparty is a branch, the reporting entity reports the counterparty’s head office LEI. For a trade with a Singapore bank branch, do not assume the branch has a distinct LEI to place in the counterparty field.

These FAQ answers address which identifier is reported and how a new identifier affects open positions. They do not, by themselves, establish an MAS duty to renew an LEI. If you are considering whether to renew an LEI, keep that decision distinct from the specific MAS reporting instructions described here.

Who is a specified person?

MAS identifies a threshold for a person that is not licensed by MAS. According to its FAQ, such a person becomes a specified person with a reporting obligation if it is resident in Singapore and its aggregate gross notional amount of specified derivatives contracts booked or traded in Singapore for the year exceeds S$8 billion. The amount is assessed on the last day of every quarter.

The test concerns specified derivatives contracts booked or traded in Singapore, not simply the existence of a bank account or an occasional request for an LEI. A business close to the threshold should review its own contract data and confirm its position with its regulator or adviser. The reporting entity should likewise establish the counterparty category before selecting an identifier from the MAS fields.

How to get an LEI in Singapore

Start by confirming the legal entity that needs to be identified. For a branch, check the head office LEI before seeking an identifier for the branch; for a company or fund, check the entity named as counterparty. Also ask whether an LEI or pre-LEI already exists, so the identifier supplied to a bank is consistent with its records.

1. Check the entity’s registration details against its relevant Singapore registration record. The GLEIF Registration Authorities list includes the ACRA Business Registry among the Singapore registration authorities.
2. Use GLEIF’s list of LEI issuing organisations to identify issuers accredited to serve Singapore. An entity can choose among issuers serving its jurisdiction.
3. If the entity needs an identifier, apply for an LEI in Singapore using the legal entity’s registration details. Give the resulting identifier to the party responsible for the relevant reporting.

For related explanations of LEI use, see the Singapore LEI articles. For this reporting question, the concrete next step is to confirm the entity and its specified-person status with the reporting party, then check the identifier it holds for that entity and any open trades.