Quick answer
There is no EU rule that requires every company to have an LEI. Most EU LEI requirements bind banks, brokers and crypto platforms, which must identify company clients by the code, wherever the client is registered. Without one, a company usually cannot trade listed securities through an EU broker or enter into most derivatives, such as currency hedges, with its bank, and many crypto platforms ask for it too. Companies that publish a prospectus or list shares or bonds on a regulated market, financial firms and, from 2028, the largest companies publishing sustainability reports must obtain one themselves.
When a bank, broker or crypto platform asks your company for a Legal Entity Identifier (LEI), the request often names a regulation: MiFID II, EMIR, MiCA or DORA. These EU rules set different LEI requirements, and only a few of them oblige your company itself.
If you already know that your company needs a code, you can order an LEI online through us. Below, we sort these rules by what they mean for an ordinary company.
Is an LEI Mandatory in the EU? Who the Rules Actually Oblige
No single EU law makes the LEI mandatory for every company. Most LEI rules oblige regulated firms instead: a broker, bank or crypto platform must report or record its clients’ transactions and identify each company client by its LEI. In most cases, your company breaks no rule by having no code, but the firm usually will not provide the service until it has your company’s LEI. Brokers call this “no LEI, no trade”.
A smaller group of rules obliges the companies themselves to obtain an LEI, mainly financial firms, companies that raise money on capital markets and the largest companies that publish sustainability reports. A third group only records the LEI of a company that already has one. The EU’s Anti-Money Laundering Regulation (AMLR), which applies from 10 July 2027, asks banks to record a company client’s LEI only where available, so EU law does not make the code a condition for an everyday business account.
The table sums up the main EU LEI requirements and when each of them applies.
| EU rule | What it covers | When a company needs an LEI |
|---|---|---|
| MiFID II and MiFIR | Shares, bonds, ETFs and other exchange-traded instruments bought or sold through an EU broker or other investment firm | Before the broker executes its first order |
| EMIR | Derivatives such as currency forwards, swaps, options and CFDs | Before the bank or broker agrees the contract |
| SFTR | Repos, securities lending and margin lending | When the company enters into such a transaction |
| MiCA | Crypto-asset services and crypto-asset white papers | Usually before the first crypto trade; stated in a white paper if the company has an LEI |
| Prospectus Regulation and Transparency Directive | Public offers of securities and companies listed on a regulated market | When it publishes a prospectus or its shares or bonds are admitted to trading on a regulated market |
| CSRD and ESAP | Sustainability reports of the largest companies | From 2028, when the company falls within the CSRD’s scope |
| DORA | Financial firms and their IT suppliers | Financial firms always; non-EU IT suppliers listed in a financial client’s register (EU suppliers can use their EUID) |
| AMLR | Customer checks by banks and other firms under anti-money laundering rules | Not required; recorded where available |
LEI Requirements for Investing and Currency Hedging: MiFIR and EMIR
Most LEI requests that reach an ordinary company trace back to two regulations, MiFIR and EMIR. A third regulation, the Securities Financing Transactions Regulation (SFTR), asks for the LEI of both parties to repos and securities lending, which few businesses outside finance use.
MiFID II and MiFIR
The Markets in Financial Instruments Regulation (MiFIR) obliges investment firms, such as brokers, to report their clients’ transactions in shares, bonds, ETFs and other instruments traded on an exchange or another trading venue. Under MiFIR’s detailed reporting rules, a firm may not provide a service that triggers such a report until it has the client’s LEI.
Banks and brokers often call this the MiFID II LEI requirement, after the Markets in Financial Instruments Directive (MiFID II), which was adopted alongside MiFIR. The requirement covers sales as well as purchases. Our guide to LEIs for company brokerage accounts shows how brokers apply it in practice.
EMIR
The European Market Infrastructure Regulation (EMIR) requires derivative contracts to be reported to a trade repository, with both parties identified by their LEI. For a typical business, the EMIR LEI requirement applies when it agrees a currency swap, option or forward with its bank to manage exchange-rate risk. It also applies to contracts for difference (CFDs) traded through an online broker. An ordinary currency exchange settled within two working days is a spot deal rather than a derivative, so EMIR does not apply to it.
Most EU businesses are not financial firms and trade well below EMIR’s clearing thresholds, the volumes above which extra duties apply. When such a business agrees a contract directly with a bank or broker rather than on an exchange, the bank or broker reports it on behalf of both parties. The business must still provide a valid LEI, and ESMA, the EU’s securities markets regulator, expects the code to be renewed every year so that the reports are not rejected. If your code has already lapsed, you can renew it and keep the same number.
Crypto-Assets: MiCA
The Markets in Crypto-Assets Regulation (MiCA) brings crypto exchanges, brokers and custodians under EU licensing as crypto-asset service providers. Under MiCA’s record-keeping rules, these providers must identify company clients by an LEI in their order and transaction records. If a company client has no LEI, the provider must obtain one for it or use another identifier defined at EU level. In practice, many platforms, including Revolut Business, ask for the code before a company’s first crypto trade.
A company that offers its own token to the public or seeks its admission to trading usually has to publish a crypto-asset white paper. The official template asks for that company’s LEI and accepts a national identifier only when it has none. If your project has reached this stage, we can help with preparing a MiCA white paper.
Raising Capital and Public Reporting: Prospectus Regulation, Transparency Directive and CSRD
EU securities and reporting rules oblige the company itself, but only if it raises money on capital markets or ranks among the EU’s largest. A company that publishes a prospectus for a public offer of shares or bonds must state its LEI in it, as the templates under the Prospectus Regulation require. Once its shares or bonds are admitted to trading on a regulated market, a company must also obtain an LEI under the Transparency Directive. It then uses the code in its annual reports and the other disclosures it publishes as a listed company.
From 2028, the EU Accounting Directive, as amended in 2023, also requires companies that publish a sustainability report under the Corporate Sustainability Reporting Directive (CSRD) to obtain an LEI. The code identifies their reports on the European Single Access Point (ESAP), the EU’s central database of company disclosures. The EU narrowed the CSRD in 2026: from the 2027 financial year, reported in 2028, it covers only companies with more than 1,000 employees and a net turnover above €450 million. Smaller companies need no LEI for it.
Financial Firms and Their IT Suppliers: DORA
The Digital Operational Resilience Act (DORA) covers banks, investment firms, insurers, payment institutions, crypto-asset service providers and other financial firms. Each of them needs an LEI to identify itself in its register of information, which lists its IT contracts, and in its reports on major IT incidents. A company applying for a financial licence, for example as a crypto-asset service provider under MiCA, should therefore plan for an LEI from the start.
IT suppliers are affected only indirectly. Their financial clients list them in the DORA register under an LEI or, for suppliers registered in the EU, under the European Unique Identifier (EUID) that their business register assigns free of charge. A supplier from outside the EU has no EUID, so it needs an LEI.
LEI Requirements for Non-EU Companies
Most EU LEI rules apply because of where the financial firm is based, not where its client is registered. A company from Switzerland, the UAE or the United States that trades through an EU broker or hedges currency risk with an EU bank needs an LEI just as an EU company does. The United Kingdom kept the same requirements in its own versions of MiFIR and EMIR after Brexit. Because the code is global, one LEI serves a company everywhere.
Getting an LEI for Your Company
If your bank or broker has asked for an LEI, or an EU LEI requirement is likely to apply to your company, we can arrange the code for you. We work with WM Datenservice, an LEI issuer accredited by GLEIF, the foundation that oversees the global LEI system. Companies from more than 50 countries can apply through our online form, and most codes arrive within one or two working days. If your bank’s request is unclear, forward us its message, and we will check it free of charge and tell you whether your company already has an LEI.
Frequently Asked Questions
No. EU anti-money laundering rules ask banks to record a company’s LEI only where one exists, so EU law does not make the code a condition for an everyday business account. Under EU payment rules, a transfer carries the LEI only if the company has given it to its bank, so payments go through without one. Banks usually ask for the code when a company wants to invest, hedge currency risk or buy crypto through them.
In most cases, no. Under MiFIR and MiCA, the duty to identify clients by their LEI lies with the broker or crypto platform: a company without a code faces no fine but may be refused the service. Under EMIR, the bank usually reports the contract for both sides. A company established in the EU must still give the bank correct details, including a valid LEI, for as long as the contract runs. Listed companies, financial firms and other companies that EU rules oblige directly must hold an LEI themselves, and national authorities can penalise a breach.
