This page explains how EMIR uses the Legal Entity Identifier (LEI) in derivatives reporting. You will learn who needs an LEI, where it appears in EMIR fields, and what validation rules expect for LEI status in the EU and the UK. Updated: 24 September 2025.
Who needs an LEI under EMIR
- Financial counterparties (FC) and non‑financial counterparties (NFC) — each counterparty is identified by LEI in EMIR trade reports.
- CCPs and clearing members — identified by LEI where applicable.
- Beneficiaries, brokers, and submitting entities — LEIs appear for these roles when reported.
- Natural persons — do not use LEIs; national identifiers apply.
Need background on roles and issuance? See Who issues LEIs (LOUs & Registration Agents) and What is an LEI?
Where the LEI appears in EMIR reports
Under EMIR, counterparties and several related entities are identified with LEIs in the trade state report. In practice, firms capture and maintain LEIs for:
- Counterparty 1 / Counterparty 2 — the two parties to the derivative.
- Entity responsible for reporting (ERR) — the submitting entity’s LEI.
- Broker / Beneficiary — where relevant to the trade.
- CCP / Clearing member — for cleared trades.
For the 20‑character structure and validation basics, see LEI code format (ISO 17442).
EU vs UK: LEI status & validation
Go‑live timelines. The EU’s EMIR Refit reporting went live on 29 April 2024. The UK’s amended UK EMIR reporting went live on 30 September 2024.
Validation expectations. LEI fields undergo format and status checks. Typically, the LEI of the reporting entity and Counterparty 1 must have an acceptable status (e.g., Issued). Some jurisdictions allow Counterparty 2 to be reported with a Lapsed status for specific action types, subject to the local validation table. Always consult the current EU/UK validation rules before filing.
Operational controls
- Capture & validate. Check LEI format and check digits; then confirm status per the applicable validation rules.
- Portfolio monitoring. Track counterpart LEIs approaching lapse; align renewal reminders with trading calendars.
- Reconciliation. Compare reported LEIs vs source systems and counterpart confirmations; resolve breaks quickly.
- UK vs EU differences. Maintain separate rule sets and effective dates for EU EMIR vs UK EMIR.
Common pitfalls
- Submitting trades where the reporting entity’s LEI is lapsed.
- Using LEIs for natural persons instead of national identifiers.
- Not updating beneficiary or broker LEIs after corporate actions.
- Applying EU validation logic to UK filings (or vice versa).
FAQ
Is there a “no LEI, no trade” rule under EMIR?
Formally, EMIR focuses on reporting rather than trading permissions. However, because missing LEIs cause reporting failures, many firms operate a practical control: no LEI, no execution for legal‑entity clients in derivatives.
Do LEIs have to be active for both counterparties?
Validation tables distinguish which roles must have an Issued status for each action type. The reporting entity and Counterparty 1 often require an acceptable (non‑lapsed) status; some action types permit Counterparty 2 with Lapsed. Always check the current EU/UK tables.
What else changed with EMIR Refit?
Key changes include ISO 20022 XML reporting, expanded fields, and the introduction of UPI alongside UTI governance. Keep separate configurations for EU vs UK timelines and field differences.
Authoritative reference: ESMA’s EMIR reporting hub provides guidelines, validation rules, and schemas. ESMA — EMIR Reporting.