FAQ
GENERAL INFORMATION ABOUT LEI
What is LEI?

The Legal Entity Identifier (LEI) is a global and unique code based on the ISO 17442 international standard that is used to identify legal entities that are parties to financial transactions and to comply with the reporting requirements in the financial markets


What is the purpose of LEI?

In accordance with the European regulation, the LEI code must be used to identify the contracting parties to financial market transactions worldwide and make it easier for regulators to recognize possible systemic risks at an early stage. The ultimate aim is to better manage financial risks


How is the LEI system organized?

The Global LEI System (GLEIS) is an international system with a federal organization that is guided by the Global LEI Foundation (GLEIF), established in June 2014 as the administrative center of GLEIS.

The supervision of the system is performed by the Regulatory Oversight Committee (ROC), consisting of more than 50 financial regulators worldwide and a variety of public sector organizations.

The Central Operating Unit (COU) manages the system under the supervision of the ROC and is responsible for applying global uniform standards and for coordinating and overseeing the actions of LOUs and their interrelationships.

The Local Operating Units (LOU) are the public or private entities that will implement the LEI system at a local level, being thus in charge of providing the identifier to the entities that request it and registering the reference data associated with this code.


What entities are likely to have a LEI code?

At this time, all companies that participate in derivatives trading need a LEI. The first recipients are the financial entities:

• Banks and financial companies

• Entities issuing equity, debt or other securities for other capital structures

• Entities listed on a stock exchange

• Entities trading stock or debt

• Investment instruments, including mutual funds, pension funds and alternative investment instruments constituted as corporate entities or collective investment agreements (umbrella funds, hedge funds, venture capital, etc.)

• Entities under the supervision of a financial regulator and their affiliates, subsidiaries and portfolio companies

• Counterparties to financial transactions

• Joint ownership

• International Branches

They cannot currently be assigned an LEI code:

- Natural persons

- Branches also headquartered in Spain


What is the format of the LEI?

The format of the internationally standardized LEI is based on the specifications provided by ISO standard 17442. It consists of 20 alphanumerical characters and follows the following pattern:

Prefix - Reserved Digits - Random alphanumeric code - Check Digits

9598 (*) 00 N60CEGKTATBG 90

(*) 9598 is the prefix allocated to Spanish LOU by the ROC


What entity information is recorded along with the LEI?

Each LEI record contains the following information about the entity:

• Official name of the legal entity

• Legal address of the entity

• The real address of the entity’s headquarters

• Country / Region of Legal Jurisdiction

• Entity Category

• LEI Code and / or Name or denomination of the associated entity when entity’s category is FUND.

• Legal form

• Number of the entity in its corresponding Registry and name of the Business Register

• LEI code from the LOU responsible of maintaining the entity’s LEI record

• Initial Registration date of the LEI

• Date of the last information update

• Date and reason for LEI expiration

• Direct parent relationship data

• Ultimate parent relationship data


What are the status of an LEI record?

All the requested LEI codes, depending on the processing moment, will have one of the following status:

• PENDING_VALIDATION: A LEI request has been submitted and is being processed and validated

• ISSUED: A unique LEI code has been issued to the applicant entity

• DUPLICATE: A LEI record determined to be a duplicate record for the same legal entity as another LEI record. The DUPLICATE status is assigned to the non-surviving record

• LAPSED: A LEI record that has not been renewed and has exceeded any allowed renewal period

• MERGED: A LEI record for an entity that has been merged into another legal entity such that the legal entity with the LEI code no longer exists as an operating entity

• RETIRED: A LEI record for an entity that has ceased its operations, without having been merged into another entity

• ANULLED: A LEI record that was marked as erroneous or invalid after it was issued

• CANCELLED: A LEI record that was abandoned before issuing the LEI code

• TRANSFERRED: A LEI record that has been transferred to a LOU different from the managing LOU

• PENDING_TRANSFER: A relationship data report for which a transfer to another LOU has been requested. The request is being processed at the sending LOU. When the receiving LOU is ready, the status will be changed to PENDING_ARCHIVAL by the sending LOU prior to completion of the transfer.

• PENDING_ARCHIVAL: This relationship data report is about to be transferred to a different LOU, after which its registration status will revert to a non-pending status. The PENDING_ARCHIVAL status serves to inform recipients of LOU-provided data files that a relationship record will be removed from that LOU’s published file after the transfer is complete.


INFORMATION ABOUT THE LEI PLATFORM IN SPAIN
Where can the LEI be requested in Spain?

Once MIFID II comes into force in January the 3rd 2018, it will be required that LEI code issuers are accredited by GLEIF. Only LEIs issued by entities (LOUs) that own this Accreditation Certificate dispatched by GLEIF will be valid.

In order to manage the accreditation the candidate LOUs must go through an accreditation process that guarantees that they have the technical and organizational means in order to verify the entities information.

In Spain, the Accredited LOU is The Public Corporation of Land and Business Registrars of Spain (CORPME), therefore LEIs can be requested using the website at www.justicia.lei.registradores.org. The validation of the information linked to an LEI Code issued by CORPME will be carried out by the Business Registrar and re-checked before issuance by CORPME.


How do I apply for an LEI?

For everything related with the LEI code, the Ministry of Justice puts at the disposal of users the public web site www.justicia.lei.registradores.org.

The legal entity requesting a LEI code will need to complete the necessary data (Registration and legal data of the company, legal addresses of the entity, information about the contact person and legal representative) in the option “Request for a global LEI” of the public web site.

Once the data have been completed and saved, the applicant will have to pay the corresponding fee through credit card or Pay Pal and will sign electronically the application form. Once the application has been signed the requestor shall upload it to the public web site in order for the validation process to continue.

For more information a User Guide is available in the following direction; https://www.justicia.lei.registradores.org/pgInformacion.


Who can request a LEI for an entity?

The LEI request will be done by a legal representative of the entity with authority to do so. It can be a legal representative of the entity that figures in the entity’s deed/public record, or it can be a third party empowered by the entity to act on its behalf.

When the application is made by a duly empowered third party, the information that accredits this empowerment shall be presented together with the application form.


Is the LEI code immediately obtained?

No. After receiving the request, LOU CORPME must verify the validity of the reference data based on the information available in different public sources. The validation authority must also ensure that there is not already an active LEI code and other requests in progress for the same entity. The validation process doesn’t have a period legally established and will vary depending on the volume of work of the validation authorities. Usually the validation period won’t exceed of five working days.


How is the LEI assignment notified?

Once the LEI code is assigned to the entity, the LEI certificate will be sent to the e-mail address of the contact person listed in the request. From this moment, the LEI code will be active.


What is the validity period of the LEI code?

The LEI code is valid for one year since the issuance date or since the last renewal date.


Is the LEI code automatically renewed?

No. It shall be the duty of the entity to request the renewal of the LEI code before its next renewal date and to keep the associated data updated. The LEI status will change to LAPSED if the entity fails to renew before the date that figures as next renewal date.

Various notifications will be sent in advance to the contact person informing of the need of renewal.


How is the LEI code and its associated data renewed?

The person authorized by the entity will access the public web site www.justicia.lei.registradores.org and will complete the request for renewing the LEI or changing its associated data. Once the data has been completed and saved, the applicant will have to pay the corresponding fee through credit card or Pay Pal and will sign electronically the application form. Once the application has been signed the requestor shall upload it to the public web site in order for the validation process to continue.

After a favorable evaluation of the request by the Registrar, the updated LEI certificate will be sent to the e-mail address of the contact person incorporated in the request form. From that moment, the LEI code will be extended for another year.

For more information a User Guide is available in the following direction; https://www.justicia.lei.registradores.org/pgInformacion.


Is it possible to transfer an LEI code from a foreign LOU to the Spanish LOU?

Yes. The transfer will be requested by the person authorized by the entity when the entity wants to transfer its LEI code from a foreign LOU to CORPME.

The request will be completed in the public web site www.justicia.lei.registradores.org. Then, it will be signed and submitted to the corresponding Business Registry in charge of validating the information.


INFORMATION ABOUT FEES AND PAYMENTS
What are the issuance and maintenance costs of the LEI?

The fees that have been set for LEI issuance and renewal are the following:

• Issuance of an LEI code: 104,16€ (VAT included)

• Renewal of an LEI code: 67,86€ (VAT included)

More price detail can be found in the contract, available in the following direction: https://www.justicia.lei.registradores.org/contratos


What payment methods are accepted?

The following payment methods are accepted:

• Credit card

• PayPal

In exceptional circumstances, if it’s not possible to carry out the payment by credit card or PayPal, bank transfers will be enabled as a payment method.


INFORMATION ABOUT ADVERTISING AND QUERIES RELATED TO LEI RECORDS
Where is it possible to find information on issued LEI codes?

The LEI codes and their associated data, issued by the Spanish LOU, can be viewed in the public web site www.justicia.lei.registradores.org, in option “LEI Search”. The access to this information is free of charge.

Additionally, the website www.gleif.org provides information on LEI codes issued by other foreign LOUs


Why is there a data file download?

GLEIF is responsible for consolidating and publishing all LEI codes issued worlwide in a centralized file that is available at the following page: https://www.gleif.org/en/lei-data/gleif-concatenated-file/download-the-concatenated-file.

This file is a concatenation of LEI data files published by each LOU around the world that meet the Common Data File Format (CDF) developed by ROC and is mandatory for all LEI issuing organizations.

The files available contain both data from the entity (Level 1) and from its relationships (Level 2).


What files are available for download?

Four files with XML format are published, that can be downloaded from the option "Download LEI files" in the public web. The four files contain the LEI records information that manage the Spanish LOU, all of which are published on a daily basis. The download is public and free.

LEI-CDF v1.0 Full file: contains all the LEI records in format v1.0 (Level 1- Who is Who). Version 1.0 will be published temporarily until all LOUs generate format v2.1.

LEI-CDF v1.0 Delta file: contains the LEI records that have been issued or updated since the publication of the previous Delta file in v1.0 format.

LEI-CDF v2.1 Full file: contains all of the LEI records in v2.1 format (Level 1 - Who is Who). Version v2.1 is the current version.

LEI-CDF v2.1 Delta file: contains the LEI records that have been issued or updated since the publication of the previous Delta file in v2.1 format.

RR-CDF v1.1 Full file: contains all entities’ relationships (Level 2- Who owns who).

RR-CDF v1.1. Delta file: contains relations between entities (Level 2-Who owns who) which have been issued or updated since the lastest Delta file publication.

Reporting Exceptions v1.1. Full file: contains all the exceptions alleged by the Legal Entities (Level 2 - Who owns Who) informing about the lack of relationships.

Reporting Exceptions v1.1 Delta file: contains all the exceptions that have been issued or updated since the publication of the previous Delta file.

GLEIF (Global LEI Foundation) publishes on a daily basis the concatenated files of all worldwide LOUs in the following direction ttps://www.gleif.org/en/lei-data/gleif-concatenated-file/download-the-concatenated-file, where it is also available all the information about the content and format of the files.


LEVEL 2 RELATIONSHIP
What is Level 2 Data?

The information available, until now, with the Legal Entity Identifier (LEI) reference data, such as the official name of a legal entity and its registered address, is referred to as ‘Level 1’ data. It provides the answer to the question ‘who is who’.

In a next step, the LEI data pool will be enhanced to include the ‘Level 2’ data that will answer the question ‘who owns whom’. This data will allow the identification of the direct and ultimate parent of a legal entity and, vice versa, in order to gain knowledge about the entities owned by individual companies.


How I do determine what data to provide?

In the "Level 2" of the data, the information to be provided is based on the accounting relationship. This means that the direct and ultimate parent with whom the entity consolidates accounts must be informed.

If the entity doesn’t consolidate accounts with other entities it must select the option ‘No’ and as reason ‘Doesn’t consolidate accounts’.

The following rules apply when providing relationship data:

• The entity must report the direct and ultimate parent with whom it consolidates accounts or provide a reason that explains why this information is not provided.

• If the direct parent and / or the ultimate parent do not have an LEI code, the entity must indicate the Name, Legal Jurisdiction, Tax Identification Code, Registration Data and the Registered Address of each of them.

• If the Legal Entity is an International Branch, it must indicate the LEI of the principal entity of which it depends. The direct and ultimate parent should not be informed.


What if I not be able to provide this information?

If the Legal Entity does not have relations or cannot report them, it will be necessary to indicate one of the following reasons:

- Natural Persons: There is no parent according to the definition used, because the entity is controlled by natural person(s) 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, because there is no known person controlling the entity (e.g., diversified shareholding).

- Legal Obstacles: Obstacles in the laws or regulations of a jurisdiction prevent providing or publishing this information.

- 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.


What policy does the Level 2 data capture handle?

INFORMATION ABOUT APPLICATIONS MADE IN THIRD PARTY INTEREST
What is an application made on behalf of another entity?

When an LEI application, renewal or update is not carried out directly by the Legal Entity through its legal representative but it authorizes a third party to carry out the application on its behalf.


How can I carry out an application on behalf of another entity?

Applications on behalf of other entities can be carried out when requesting individual issuance of LEIs and bulk LEI issuance.

In case of carrying out an individual LEI request in behalf of another entity, it can be carried out directly in this webpage indicating in the required fields that the application is being made in behalf of another entity. In such case, it will be asked to inform about the necessary data that guarantees it has the Legal Entity’s authorization in order to carry out the application on its behalf.

In case of carrying out a bulk request, the process followed will be different (see FAQ ‘Information Bulk Applications’). In this case, it will also be asked to inform about the necessary data that guarantees it has the Legal Entity’s authorization in order to carry out the application on its behalf.


What normative regulates an LEI application on behalf of another entity?

The normative that regulates the application on behalf of another entity is the Resolution of 2017, 11th April of the Directorate General of Registers and Notaries (DGRN) that establishes the minimum data that the presenter has to present when carrying out the application.

In particular it's required that:

1. The presenter (submitter) provides the necessary information to guarantee that it has asked for express authorization from the Legal Entity to act on its behalf.

2. The presenter (submitter) assumes the responsibilities that can derive from making the application without the Legal Entity's authorization.

3. The presenter (submitter) is responsible of preserving the evidences that guarantee the authorization.


INFORMATION ABOUT BULK APPLICATIONS
What is the bulk service process?

The bulk service is a utility offered by the Spanish LOU to facilitate the application for bulk LEI issues and renewals. It enables carrying out multiple applications at once for different Legal Entities.


How can I carry out a bulk application?

To carry out bulk applications the applicant shall access the following web page: https://www.justicia.lei.registradores.org/pgCargaMasiva and follow the instructions there indicated.


CONTRACT AND TERMS OF USE
Where can I find the Contract and the Terms of Use?

In the following direction: https://pre.www.justicia.lei.registradores.org/contratos, can be found the contract signed between the LOU and the legal entity and the Terms of Use that the entity accepts when applying for an LEI.