Applicability of Legal Entity Identifier (LEI)



Quick Summary
The Legal Entity Identifier (LEI) is a global reference number that uniquely identifies parties in financial transactions. It's essential for regulatory compliance and transaction reporting. Recent SEBI circulars mandate LEIs for entities involved with non-convertible securities, securitised debt instruments, and security receipts, with specific deadlines. Additionally, RBI circulars require LEIs for non-individual borrowers with significant aggregate exposure to banks and financial institutions, and for RTGS/NEFT transactions exceeding ₹50 crore.

The Legal Entity Identifier (hereinafter referred to as "LEI") is a global reference number that uniquely identifies every legal entity or structure that is party to a financial transaction, in any jurisdiction. Legal Entity Identifier India Limited will assign LEIs to any legal identity including but not limited to all intermediary institutions, banks, mutual funds, partnership firms, companies, trusts, holdings, special purpose vehicles, asset management companies and all other institutions being parties to financial transactions. LEI will be assigned on application from the legal entity and after due validation of data. For the organization,

Legal Entity Identifier (LEI): Who Needs One

Legal Entity Identifier will

  • Serve as a proof of identity for a financial entity.
  • Help to abide by regulatory requirements.
  • Facilitate transaction reporting to Trade Repositories.

Applicability of Legal Entity Identifier

SEBI Circular for Non- Convertible Securities, securitized debt instruments and security receipts

SEBI Circular requires the following entities are required to obtain -

1) Debenture Trustee
2) Asset Reconstruction Companies (ARCs)

Note: These entities to obtain LEI Number by September 30, 2023

3) Issuer who have listed or propose to list Non- Convertible Securities.
4) Securitised Debt Instrument and
5) Security Receipts.

   

Further, issuers proposing to issue and list non-convertible securities, on or after September 01, 2023, shall report their LEI code in the Centralized Database of corporate bonds at the time of allotment of the ISIN. Similarly, issuers proposing to issue and list securitised debt instruments and security receipts, on or after September 01, 2023, shall report their LEI code to the Depositories at the time of allotment of the ISIN. The requirements are tabulated below:

Category of security

Relevant Regulation

Applicability

Timeline

Non- Convertible Securities

SEBI (Issue and listing of Non- Convertible Securities) Regulation,2021

Issuer proposing to issue and list non-convertible security.

On or after September 1, 2023

Issuer having outstanding listed non-convertible security as on August 31, 2023.

On or before September 1, 2023

       

Securitised Debt Instrument and Security Receipts

SEBI (Issue and listing of Securitised Debt Instrument and Security Receipts) Regulation,2008

Issuer proposing to issue and list Securitised Debt Instruments or Security Receipts.

On or After September 1, 2023

Issuer having outstanding listed Securitised Debt Instrument and Security Receipts as on August 31, 2023

On or before September 1, 2023

   

RBI Circular for NEFT/RTGS Transactions

In accordance with RBI Circular LEI No. is required for all payment transaction of value 50 Crore or and above undertaken through RTGS/NEFT.

Explanation:

  • The circular refers to any single transaction done through RTGS/NEFT of value 50 crore above during the year.
  • The transaction includes FX Payments, Money Market Payments, Vendor Payments, Inter-company payments or any other
   

RBI Circular for Non-Individual Borrowers

RBI Circular states that non-individual borrowers having aggregate exposure of ₹5 crore and above from banks and financial institutions shall be required to obtain LEI codes as per the timeline mentioned below:

   
 

Total Exposures

LEI to be obtained on or before

Above ₹25 crore

April 30, 2023

Above ₹10 crore, up to ₹25 crore

April 30, 2024

5 crore and above, up to ₹10 crore

April 30, 2025

   

IRDAI Circular for Insurer and Corporate Borrowers

  • This Circular applicable to both term loan borrowers and debenture issuer.
  • Debentures, Term Loan as well as Bonds both would be included in computing overall exposure which will be either in form of term loan or debenture or any other form of debt.
 

Conclusion

The LEI is designed to enable the identification and linking of parties to financial transactions to manage counterparty risk. Its goal is to help improve the measuring and monitoring of systemic risk and support more cost-effective compliance with regulatory reporting requirements.

 

FAQ :

The LEI is a global reference number that uniquely identifies legal entities or structures involved in financial transactions across any jurisdiction.

SEBI circulars require Debenture Trustees and Asset Reconstruction Companies (ARCs) to obtain an LEI by September 30, 2023. Issuers listing or proposing to list Non-Convertible Securities, Securitised Debt Instruments, and Security Receipts also need an LEI.

Issuers proposing to issue and list non-convertible securities on or after September 1, 2023, must report their LEI code at the time of ISIN allotment.

An LEI number is required for all payment transactions valued at ₹50 crore or above undertaken through RTGS/NEFT.

Non-individual borrowers with an aggregate exposure of ₹5 crore and above from banks and financial institutions have specific LEI deadlines: above ₹25 crore by April 30, 2023; above ₹10 crore up to ₹25 crore by April 30, 2024; and ₹5 crore up to ₹10 crore by April 30, 2025.

The IRDAI circular applies to both term loan borrowers and debenture issuers, including debentures, term loans, and bonds when computing overall exposure.




About the Author

corporates

Why Affluence Advisory for any Tax Compliance services? Affluence Advisory Pvt Ltdis a multi-disciplinary consulting and compliance firm that is managed by a specialized team of Chartered Accountants, Company Secretaries, Corporate Lawyers, and Other Professionals who are committed to providing a quality experience ... Read more

Click here to Login and post comments    OR


Related Articles


Loading


Popular Articles





CCI Pro

CCI Articles

submit article


Company
ARTICLESHIP 10 July 2026
Article Assistant

N S Gokhale & Co

Thane

CA Inter

View Details
Company
22 July 2026
Senior Chartered Accountant

SKSS

Patna

CA

View Details
Company
ARTICLESHIP 16 July 2026
Article Assistant

Sahil Agarwal & Company

Mumbai

CA Inter

View Details
Company
28 July 2026
Senior accountant

RJ Public School

Bengaluru

B.Com

View Details
Company
Featured 16 July 2026
CA Inter, CA Intermediate, CA IPCC, CA CPT, CA SemiQualified

Vakilsearch.com

Chennai

CA Inter

View Details
Company
11 July 2026
CA semi qualified

Vakilsearch.com

Chennai

CA Inter

View Details
Company
29 July 2026
ACCOUNTANT

ONESTEP GST SOLUTION

New Delhi

B.Com

View Details
Company
Featured 16 July 2026
Semi Qualified Company Secretary

Vakilsearch.com

Chennai

CS

View Details
Follow