MiFID II regulation – LEI required
MiFID II (Markets in Financial Instruments Directive) and MiFIR (the accompanying regulation) require investment firms to report transactions using Legal Entity Identifiers (LEIs). If a client eligible for MiFID II reporting does not have an active LEI, the firm must refuse the trade—this applies across equities, bonds, derivatives, and many structured products in the UK and EU.
Who must hold an LEI?
- **Investment firms** – Broker-dealers, banks, and trading venues executing transactions in EU/UK regulated markets.
- **Clients subject to reporting** – Corporates, trusts, funds, and other legal entities. Retail individuals are typically exempt, but sole traders operating as legal entities may require one.
- **Third-country firms** – Non-EU/UK firms trading on EU/UK venues must still provide an LEI to comply with MiFIR transaction reporting.
When LEI lapses block trades
Trade repositories and Approved Reporting Mechanisms (ARMs) reject reports with lapsed LEIs. Firms must monitor expiry dates and ensure clients renew annually. “No LEI, no trade” remains the rule since MiFID II went live in 2018.
How to keep MiFID II compliant
- Require LEIs during onboarding and refresh due diligence before execution.
- Validate LEI status against GLEIF’s daily files or via an API.
- Automate renewal reminders (GlobalLEI provides alerts at 90/60/30 days).
- For urgent trades, assist clients with same-day LEI issuance or renewal via Express processing.
Record-keeping
Investment firms must maintain documentation for the LEI, the authorisation to trade, and any exemptions. Store the LEI reference alongside MiFID II client classifications so your reporting systems always submit a valid identifier.
If you need help aligning MiFID II controls with LEI issuance or renewal workflows, GlobalLEI can provide compliance checklists, API access, and managed renewal services.
