LEI Renewal in the US: Annual Checks and the DTC Deadline

LEI renewal is due by the Next Renewal Date shown in the entity’s record. The entity confirms or updates its reference data with its LEI issuer so the data can be re-validated each year, even if nothing has changed. In the United States, DTC Participants also face a separate December 12, 2026, deadline to provide a valid LEI.

What this means in the United States

DTC Important Notice 25129-26 (rule filing SR-DTC-2025-009) sets December 12, 2026, as the deadline for DTC Participants to provide a valid LEI. The requirement applies to DTC Participants, not DTC Limited Participants or CDS Participants. A broker-dealer that is a DTC Participant should check its LEI record before that deadline.

Under the notice, a Participant that fails to provide a valid LEI within 60 calendar days of being notified could face disciplinary sanctions, including a fine. That notification period should not be confused with the LEI record’s Next Renewal Date or with any grace period set by an LEI issuer. The DTC notice addresses provision of a valid LEI; it does not state that DTC requires renewal as such.

DTC uses GLEIF as a reference source for LEI information and encourages Participants to keep their GLEIF records accurate and up to date. A Participant should therefore check both its identifier and the information displayed in its GLEIF record. If the record shows LAPSED, the LEI remains valid under GLEIF’s guidance, but the Participant should check its position with DTC or its adviser rather than assume how DTC will treat that status.

A separate US standard appears in 12 CFR 15.2 (OCC, Financial Data Transparency Act joint data standards): the legal entity identifier joint standard is ISO 17442 – the LEI. A US bank holding company reviewing its LEI data under those standards can read more in the FDTA LEI requirements for US companies. The DTC deadline and the annual LEI renewal date remain distinct matters.

LEI renewal: key points

• Find the registration status and Next Renewal Date in GLEIF LEI Search. The search is free and does not require registration.
• Notify the managing LEI issuer when the entity’s reference data changes; do not wait for the next renewal.
• Renewal includes checking the information with the entity and re-validating reference data against a third-party source.
• If renewal remains incomplete after the Next Renewal Date and the issuer’s grace period, the status becomes LAPSED. The LEI remains valid.
• A multi-year contract does not remove the annual data review.

When is an LEI renewal due?

The deadline for an individual record is its Next Renewal Date. GLEIF – LEI-CDF 3.1 format defines that field as the date by which the LEI must be renewed and re-certified. Use the date displayed for the entity’s own record rather than assuming that every entity shares the same renewal schedule.

In GLEIF blog – The Importance of Timely Renewal of LEIs (2015), GLEIF quotes the LEI Regulatory Oversight Committee: an issuer must re-validate reference data regularly and no later than one year after the previous validation check. The Next Renewal Date is agreed between the entity and its issuer, but it must be no later than one year after the previous verification. Unchanged details are not an exception to renewal by the target date.

What does the annual data check involve?

Renewal checks whether the reference data still describes the entity accurately. The issuer verifies the relevant information with the entity and re-validates the data against a third-party source. An entity whose details have changed must tell its managing issuer rather than wait for that annual check.

GLEIF – Data Quality Management explains that the entity and issuer review and re-validate reference data at least annually. Even if the published details appear unchanged, the review must still take place. An entity preparing to renew should check its record, identify any changes and respond to the issuer’s request to confirm the information.

What happens if renewal is missed?

If renewal is not completed by the Next Renewal Date and within the grace period set by the issuer, the registration status becomes LAPSED. GLEIF’s data format describes LAPSED as not renewed by that date where public sources do not indicate that the entity has ceased operating. The issuer sets the grace period, so do not assume its length from another record.

A lapsed LEI remains valid; LAPSED indicates that renewal is behind schedule. The displayed status may prompt questions from a counterparty, but the record alone does not establish how a particular bank, broker or DTC will apply its requirements. Check a counterparty-specific request with that counterparty or an adviser.

Can an LEI be renewed for multiple years?

Some issuers offer multi-year contracts instead of annual arrangements, as described in GLEIF – The Legal Entity Identifier (LEI): Questions and Answers (2024). A multi-year booking covers several years, but the entity and issuer must still review and re-validate reference data every year. The entity must also report changes to its managing issuer when they occur.

Situation	What to check or do
Next Renewal Date approaching	Confirm or update reference data with the issuer by the date shown in the record.
Multi-year arrangement	Make sure someone can respond to the issuer’s annual data check.
LAPSED status	Contact the issuer about the overdue renewal; the LEI remains valid.
DTC Participant	Check the GLEIF record and the separate December 12, 2026, deadline to provide a valid LEI.

An entity that wants to change its managing issuer can consider a transfer to another LEI issuer. Changing issuer does not remove the need for the annual data review.

What do the renewal figures show?

GLEIF – The LEI in numbers, Q3 2026, published October 22, 2026, reported an overall renewal rate of 57.1% for Q3 2026. The rate was 61.1% in EU jurisdictions and 51.1% in non-EU jurisdictions. Those system-wide figures cannot establish whether a particular US entity has completed renewal.

GLEIF also reported 3.19 million active LEIs and 90,000 new LEIs in that quarter. At its end, 88.1% of all LEIs were fully corroborated, meaning all reference data had been validated against public authoritative sources. For other explanations of LEI records and requirements, see the US LEI articles; for an individual entity, check its live record.

LEI renewal checklist

1. Find the entity’s record in GLEIF LEI Search and note its registration status and Next Renewal Date.
2. Compare its reference data with the entity’s current details and report changes to the managing issuer.
3. Respond to the issuer’s request to confirm information for re-validation.
4. Complete the LEI renewal by the record’s Next Renewal Date, even if no details have changed.
5. Check the displayed status and next renewal date again. If the entity is a DTC Participant, separately check what it needs to provide to DTC by December 12, 2026.