The LEI registration process should take no more than 2 minutes, assuming the right information is at hand.
Filling out relevant information
Since the application form is connected to many of the business registries, the form can automatically fill in most of the entity data (depending on the jurisdiction). This is unfortunately not the case with entities that are not listed in official registries (such as Trusts or Schemes). With these types of entities, the LEI registration process involves a couple of more steps.
The information required in the initial registration stage is the company name, registration number and legal and headquarters address. Additionally, the applicant's contact details are required. This data will not be published to the GLEIF database, but is used by the Registration Agent for communication, if needed.
LEI Lookup is a Registration Agent and will handle the applications for LEI codes. We serve as an agent between legal entities, LOUs and GLEIF (Global Legal Entity Identifier Foundation) which is the centre for all LEI data.
Data validation and approval
After completing the payment, we perform a quick check of the data to ensure there are no outstanding issues. Once this is done, we submit the application on the customer's behalf to our partner LOU who will validate the provided data against the relevant business registry / the provided documents. This process should not take longer than 24 hours, however it is often completed much quicker. At times it is possible to receive the LEI code in just 10 minutes!
Once the application has been approved by GLEIF, the customer will receive the LEI code and as soon as it is published to the GLEIF database, it can be used for legal entity identification.
Documents to provide for an LEI application
There can be instances when the entity data cannot be immediately validated from the relevant business registry. Additional documents are then requested from the applicant. The process is smoother if relevant documentation is prepared beforehand. The documents should provide up to date information about the entity that requires the LEI code. The data that has to be validated is the entity name, registration number (if applicable), legal and headquarters address and empowered persons.
Some examples of relevant documentation include:
- Certificate of Incorporation
- Certificate of Incumbency
- Trust Deed
- Power of Attorney or legal letters
- Legally-binding or recognised documents that confirm LEI data
A full list of required and supporting documents can be found on the Required Documents page on the official GLEIF website.
Requests for additional information
There may be cases where difficulties are encountered during the application process. Contact us as soon as any assistance is required!
Data clarification requests can come from the Registration Agent's side too. Ultimately, the issuing LOU is responsible for data accuracy and quality, which is the reason for additional questions in some cases. There is a strict check for duplicate LEI's, as each legal entity can only have one LEI code issued. Data quality is a top priority for GLEIF, which is the reason for duplicate checks and requests for additional documentation.
In order to expedite the process of applying for an LEI code, it is best to ensure that the entered data is correct, up to date, and corresponds with the data presented in the business registries. In case of any doubts, it is best to ask for clarification from the LEI service provider before submitting the application. This is to avoid delays in the system and to ensure the application is successful on the first submission.
Paying for the LEI registration
Payment is also a part of an LEI registration. The GLEIF surcharge is $11 USD per one-year application, which is included in the LEI price of LEI Lookup. In most cases, a multi-year registration is the most cost-effective option since it reduces the yearly costs. However, a single-year registration is perfectly valid if the LEI is required for a shorter time-period. LEI codes are offered at different rates online and the pricing strategy is up to the service provider. Since LEI codes are standardised, it does not matter which LOU issues the LEI, as long as it is published to the GLEIF database.
Renewing an LEI
LEI codes need to be renewed once every year in order to guarantee that the LEI data is accurate and up to date.
In case of a multi-year registration, the initial application and subsequent renewals will be handled by LEI Lookup. If the initial application was made for one year, the renewal needs to be applied for. This process is simple, as the LEI data already exists in the GLEIF database. Any changes to the entity data should be submitted with the renewal application.
The LEI data is validated again during the renewal process, against the data in the business registry. If there are changes in the registry, the LEI data will be changed according to the registry. If there are any changes in the registry that require clarification from the applicant (company merged or liquidated, authorised persons changed), LEI Lookup will contact the customer for clarification or supporting documents.
If the LEI is not renewed in time, its status will change from Issued to Lapsed. A lapsed LEI has the same effect as having no LEI code at all - there will not be any access to financial markets and trading will not be possible. This is why we recommend to always keep the LEI code active and the data updated.
Transferring an LEI
It’s also possible to transfer an LEI to a different LOU. LEIs are managed by the LOU that initially registered the application. However, it’s possible for you to switch management to another LOU if required. The transfer retains the LEI code, but the management will change to another company. This can be useful if you are not satisfied with the services of your previous LOU and would like to work with a different company.
There is no transfer fee involved when transferring an active and issued LEI. However, you will be required to pay the renewal fees of the new LOU that you are working with. Transferring an LEI will require some cooperation between LOUs, so the process can take up to 7 days.
Reporting Level 2 data for an LEI
When registering an LEI, Level 2 data will need to be provided. This is the data used to answer the question “who owns whom” and involves any parent or child company data related to the legal entity. According to GLEIF, a parent company can be reported if it owns more than 50% and consolidates the financial statements of the child entity. However, reporting Level 2 data is voluntary. There are many exceptions to choose from if the Level 2 data cannot or should not be reported. These exceptions include:
- Natural Persons: There is no parent entity according to the definition used because the entity is controlled by a natural person or persons without any intermediate legal entity meeting the definition of accounting consolidating parent.
- Non Consolidating: There is no parent according to the definition used, because the entity is controlled by legal entities not subject to preparing consolidated financial statements.
- No Known Person: There is no parent according to the definition used in the Legal Entity Identifier Foundation because there is no known person controlling the entity (e.g., diversified shareholding).
- Non-Public: For all the below use cases
- Legal Obstacles: Obstacles in the laws or regulations of a jurisdiction prevent providing or publishing this information. The entity can not publish a parent entity in the Global LEI number database.
- Consent Not Obtained: The consent of the parent was necessary under the applicable legal framework and the parent did not consent or could not be contacted.
- Binding Legal Commitments: Binding legal commitments (other than the laws or regulations of a jurisdiction), such as articles governing the legal entity or a contract, prevent providing or publishing this information.
- Detriment Not Excluded: The child entity has sought to consult the parent entity about the reporting of the parent information but could not confirm the absence of detriment in a way that can appropriately prevent liability risks for the child entity.
- Disclosure Detrimental: The disclosure of this information would be detrimental to the legal entity or the relevant parent. This will include reasons generally accepted by public authorities in similar circumstances, based on a declaration by the entity.
The Level 2 data is validated from annual financial statements of the parent company - these will need to be provided by the applicant.
Contact us for more information
If there is any trouble with the LEI registration or more information is required, do not hesitate to get in touch with us as soon as possible. We are more than happy to assist you and offer advice on your LEI application to ensure a smooth registration.