Global Legal Entity Identifier Foundation
Annual Report
2022
Chair’s Statement
3
CEO’s Statement
4
The LEI in 2022
5
Regulation Supporting ‘One Global Identity for Business’: 2022 in Review
7
Strategic Priorities: Pushing New Boundaries in Identity Management
8
Consolidated Financial Statements
10
Notes to the Consolidated Financial Statements
15
Independent Auditor’s Report
34
Overview of Professional Advisors
35
Abbreviations
36
Contact Us
37
Contents
2022 Annual Report
2
Chair’s Statement
Throughout 2022, economic participants globally have
acclimated to living with COVID-19 as an endemic disease and
proceeded to resume business as usual. The ‘reopening’ of
China at the end of the year signified that the international
business community and its supply chains might soon regain a
degree of operational normality.
The supply chain disruption experienced in recent years
emphasized our increasing global reliance on seamless
and efficient cross-border trade activities. For those close
to the Global Legal Entity Identifier Foundation (GLEIF),
this inevitably shone a light on the criticality of having a
universally recognized, standardized, and verified entity
identifier – such as the Legal Entity Identifier (LEI) – that
enables trusted identity management to support efficient
and transparent international supply capabilities.
The value of the LEI in this context is supported by the
globally representative Regulatory Oversight Committee
(ROC), the body which oversees policy decision for the Global
LEI System. The confidence that regulatory oversight bestows
on the integrity of LEI data significantly reduces uncertainty,
and therefore friction, in cross-border business activities.
From another perspective, the LEI’s value is also linked to the
advances made by GLEIF relative to the verifiable LEI (vLEI). In
2022 great progress has been made in accelerating the path
to LEI digitization, and this will facilitate cross-border trade
for all participants within the global economy in the near to
mid-term.
Expanding GLEIF’s
footprint in Asia
In anticipation of the post-pandemic return to ‘normal’
business operations, GLEIF, in conjunction with the ROC,
created a strategic plan in 2022 to support the growth of
LEI deployments in Asia with an expanded physical footprint
in the region.
The regulatory drive for LEI adoption in Europe has been
broad and widely supported, and we anticipate that the
Financial Data Transparency Act, which was passed by US
Congress in December 2022, will provide a huge opportunity
to boost LEI adoption in the US. However, initial LEI uptake
across the Asia-Pacific (APAC) region accelerated more
slowly. Presently, however, a number of regulatory initiatives
combined with the GLEIF/ROC strategic initiative within the
region are contributing to an increasing momentum of LEI
issuance, despite legacy challenges from the pandemic. Some
noteworthy flagship LEI developments in key Asian markets
last year included the following:
•
In Japan, a proof-of-concept initiated by GLEIF
demonstrated that embedding the LEI within eSeals brings
significant international interoperability and enhanced
trust advantages. The initiative, which encourages and
facilitates efficient and secure cross-border transactions
using a digital framework, continues to make progress.
•
Great strides were made in India toward improving the
security and efficiency of cross-border payments when the
Reserve Bank of India moved to require the use of the LEI
in large payment transactions.
•
Likewise, China continued to accelerate adoption of the
LEI through strong governmental and regulatory support.
To complement an established local office in Japan, and to
allow closer future collaboration between GLEIF’s experts and
LEI users, GLEIF’s on-the-ground presence will be boosted in
early 2023 with the opening of offices in Singapore and New
Delhi, India.
Strengthening core operations
Throughout the past year, participants within the Global LEI
System have invested time and energy to improve the Global
LEI System’s reach and its capacity to create LEIs.
LEI issuers around the world have done an outstanding job of
maintaining their operations and providing high-quality LEI
issuance services despite the disruption experienced in recent
years and while also expanding coverage to include trust fund
entities. In addition, the GLEIF team continued to work with a
variety of Business Registrants on a new initiative to enable
bulk registration.
A digital trust framework to
stimulate voluntary LEI adoption
In the past year, GLEIF made significant progress towards
a strategic objective unveiled in 2021: the creation of
a digitally trustworthy version of the LEI (the vLEI) and
an infrastructure to support its adoption. In addition to
publishing the vLEI Ecosystem Governance Framework, which
was based on the Trust over IP Governance Metamodel, the
key foundational elements for successful implementation
were also established. While it is still early days relative to
vLEI infrastructure development, there is an elevated level
of interest and enthusiasm from engaged stakeholders
in this digital global identity framework. This comes as no
surprise. The capacity for the vLEI to verify organizational
identity while promoting trust and transparency in this rapidly
digitizing global economy, is unparalleled. It will be a key
driver for adoption of the LEI more broadly, beyond mandates
and regulation. While we expect the model to take some time
to gain momentum, we anticipate early adoption to gather
pace throughout the year ahead.
2023: A year of opportunity
In many respects, 2022 proved to be a year of transition,
both for the world at large and for the Global LEI System.
Importantly, in the face of ongoing and emerging global
challenges, GLEIF has continued to grow and future-proof the
Global LEI System while driving the total LEI population higher
than ever before. For these achievements I wish to offer
sincere thanks to Steven Joachim, the outgoing Chairman
of GLEIF who helped to lead the organization throughout
2020-2023, for his dedicated service, commitment to GLEIF
and valuable contributions. I also extend heartfelt thanks
to the ROC, the GLEIF Board, all my GLEIF colleagues and to
every GLEIS stakeholder. Your dedication and contributions
bring us ever closer to achieving GLEIF’s vision: one global
identity for each business worldwide, including a digital
identity. I look forward to working alongside you in the year
ahead as we continue to capitalize on the momentum already
achieved and find new opportunities to bring transparency
and trust to an increasingly interconnected digital world.
2022 Annual Report
3
Teresa A Glasser
Chair of the Board of Directors,
Global Legal Entity Identifier
Foundation (GLEIF)
Stephan Wolf
Chief Executive Officer,
Global Legal Entity Identifier
Foundation (GLEIF)
CEO’s Statement
GLEIF’s commitment to deliver a world-class universal entity
identity management ecosystem was rewarded in 2022 with
impressive growth on multiple levels. At the end of the year,
2.19 million active LEIs were reported globally. Annual growth
of nearly 13% had driven global LEI volumes higher than they’ve
ever been before. This significant scale-up was supported by
an increase in enabling stakeholders within the Global LEI
System; throughout the year we warmly welcomed a host of new
participants to our ecosystem, including Validation Agents, LEI
and vLEI issuers, and mapping partners. As a result, the Global LEI
System is currently stronger and more expansive than ever before.
Yet growth last year went far beyond that which can be
measured quantitatively. GLEIF continued to amplify the LEI’s
value, expanding its unique capability in the digital world while
enhancing the quality, scope and transparency of data housed
within the Global LEI Index.
GLEIF’s focus on increasing the relevance and value of the LEI
led to a rise in governments, authorities and other influential
organizations championing it. Notably, support was not
only in favor of regulatory agendas but also of bringing
benefits to private and public sector use cases outside of
those traditionally mandated. The proliferation of new LEI
applications being considered and consulted on around the
world demonstrates the universal applicability of one global
identity behind every business.
Enabling global identity. Protecting
digital trust. Introducing GLEIF’s
new brand identity
A key priority for GLEIF in 2022 was the continued development of
an infrastructure that supports the implementation of a digitally
verifiable version of the LEI – the vLEI. In line with GLEIF’s
vision, ‘one global identity behind every business’, the Global
LEI System provides open and reliable data to enable legal
entities to be identified unambiguously. Yet there is a real need
for a cross-border organizational digital identity management
infrastructure to extend transparency and confidence to all
digital transactions as well as those that happen offline.
It has been natural for GLEIF to evolve the utility of the Global
LEI System to create a digital trust ecosystem for legal entities
everywhere. While GLEIF first unveiled plans for a vLEI technical
infrastructure and issuance process in 2021, these past twelve
months have been hugely progressive in terms of laying
down the governance framework, building an operational
implementation model and broadening the LEI’s relevance in
both the offline and digital worlds.
To embrace and highlight this transformation within the Global
LEI System, GLEIF unveiled a new look in 2022. A modern, clean
brand identity was created, including a new logo, strapline,
and trust marks, ensuring that this milestone evolution of the
Global LEI System was mirrored by an outward transformation.
The intention was to help the GLEIF ecosystem better convey
the LEI’s central purpose: to create lasting and verifiable trust
between legal entities everywhere – whether offline or online.
A focus on data: Quality
and scope enhancements
Elsewhere, updated policies and strategic collaborations
throughout 2022 greatly enhanced the scope, transparency,
and utility of LEI data, leading to improvements in the overall
value of data within the Global LEI index – which will benefit
data users globally.
New ROC policies outlined new LEI data formats which
expanded the scope of data contained in each LEI, creating yet
more transparency in the global marketplace. The three key
changes were:
•
The structured classification of public sector entities
allowing General Government Entities or International
Organizations to be recognized. By the end of 2022,
over 4,800 government entities and 27 international
organizations had been reported.
•
A requirement for the inclusion of Legal Entity Event data,
such as a name change, a change in legal entity form, or
mergers and acquisition. This enables LEI data to deliver
the most accurate and up-to-date information about legal
entities as they evolve. Over time, this will stimulate the
retirement of old LEIs and the creation of new ones.
•
Updates to the way entity relationships which impact
investment funds are recorded, to facilitate the
standardized collection of fund relationship information
at the global level. At the end of 2022, over 88,000 legal
entities reported fund relationships.
Separately, GLEIF and its partner Sociovestix Labs collaborated
to create a new open-source tool that uses machine learning
algorithms to assess and improve data quality. The tool, known as
Legal Entity Name Understanding (LENU), enables automated
assignment of Entity Legal Form (ELF) Codes based on an entity’s
legal name and jurisdiction. LENU is freely available on GitHub.
Building momentum for
mass LEI deployment
GLEIF continued to push boundaries in 2022 by supporting LEI
adoption both within and beyond traditional regulated markets.
The strong regulatory support for the LEI within its historical
playground of capital and money markets has given it
unimpeachable credentials for enabling trust and transparency
within complex identity management ecosystems. This
paved the way for champions such as the Financial Stability
Board (FSB), the European Commission (EC), the Bank for
International Settlements (BIS) and the International Chamber
of Commerce (ICC) to advocate for its use last year within the
context of cross-border payments, open finance, trade finance
and supply chain use cases, respectively.
The LEI has also been making headway in the area of
Environmental, Social and Corporate Governance (ESG).
It’s widely understood that the lack of standardized entity
identification is a real challenge in ESG reporting, data
collection, and data exchanges, making it difficult to find,
compare and consume ESG data globally and resulting in a
lack of transparency and inefficiencies. Influential bodies in
the sustainability space have now concluded that the LEI
offers an established and openly available solution. In 2022,
collaborations between GLEIF and ESG bodies such as OS-
Climate and Carbon Call laid strong foundations for the LEI to
have real impact in ESG reporting 2023 and beyond.
With so many influential supporters recognizing the relevance
and value of the LEI over such a wide application landscape, it
is anticipated that momentum will continue building into 2023
and beyond.
I wish to thank all of my GLEIF colleagues, as well as partners,
and stakeholders who support and enable the organization’s
success. In particular, I’d like to thank Steven Joachim, GLEIF’s
outgoing Chairman who served throughout 2020-2023 and
whose leadership and dedication to the role contributed to
GLEIF’s progress. I look forward to working with his successor
and GLEIF’s Board in the coming year.
2022 Annual Report
4
The LEI in 2022
Active LEIs by region:
Worldwide LEI adoption reached a new
milestone in 2022: 2+ million active LEIs
2.19
million
active LEIs
globally
252,000
total LEIs issued
in 2022
12.9%
annual growth
rate*
250
jurisdictions
with LEI
services
As of 2022, Dec, 31
New collaborations
and partners broadened
the scope of the
Global LEI System:
A new LEI issuer
The first vLEI issuer
Two new identifiers
mapped to the LEI
Market Identifier Code
(MIC)
Global Company ID
Three new Validation Agents
*The annual growth rate is based on new issuance in 2022 compared with total number of active LEIs in 2021.
2022 Annual Report
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Americas
402,967
Europe
1,466,185
Africa
9,745
Oceania
33,494
Asia
278,961
Top 5 countries by LEI volume:
269,023
US
174,651
Germany
174,065
UK
157,393
Italy
137,558
Spain
Top 5 countries by renewal rate
1
:
91%
Japan
88.5%
Luxembourg
87.3%
Finland
81.6%
Norway
81.2%
Liechtenstein
Top LEI growth jurisdictions in 2022:
5 most competitive markets
2
:
New data available in the Global LEI System
At the end of 2022 there were:
• Over 4,800 government entities
• Over 88,000 legal entities reporting fund relationships
• 27 international organizations
Malta Portugal Bulgaria Norway Marshall
Islands
1
Renewal rates
Renewal means that the reference data,
i.e., the publicly available information on
legal entities identifiable with an LEI, is
re-validated annually by the managing
LEI issuer against a third-party source.
2
Competitive markets
So called ‘competitive markets’ refer to
those with over 1,000 LEIs, based on the
number of LEI issuers providing services
in the jurisdiction. The most competitive
markets are those with the most LEI issuers
per jurisdiction, with similar market share.
The LEI in 2022
Continued growth across
the Global LEI System
Global trends in LEI issuance
2022 Annual Report
6
+42.7%
3,526 total
active LEIs
Iceland
+48.3%
105,346 total
active LEIs
China
+27.8%
6,382 total
active LEIs
+43.2%
109,359 total
active LEIs
+157.1%
2,434 total
active LEIs
Saudi Arabia
India
Turkey
Regulation
Supporting
‘One Global
Identity for
Business’:
2022 in Review
Regulatory authorities across
the world recognize the
value of the LEI as a mandated
component of an identity
management ecosystem. At the end of 2022, LEI use was
either required or recommended across an unprecedented
number of existing or proposed regulatory activities.
Mandates
*
for LEI usage:
234
regulations
Recommendations
for LEI use:
The LEI is being used by regulators
worldwide to verify counterparty
identification related to:
Champions of the LEI:
Jurisdictions
globally mandating
the LEI:
*
The term ‘mandate’ refers to regulations where the LEI
is either the only allowed identifier or one of multiple
accepted identifiers.
policy papers or recommendations published by
international or regional organizations.
22
61
➜ Capital markets
➜ Trade and transactions
➜ Customs
➜ Payments
➜ Crypto-assets
➜ Digital finance
➜ Supervisory reporting
➜ Non-financial reporting
➜ Insurance
➜ Corporate debt lending
➜ Anti-money laundering
➜ Bank of England
➜ Bank for International Settlements
➜ Business at OECD
➜ European Commission
➜ European Systemic Risk Board
➜ Financial Stability Board
➜ Insurance Regulatory and
Development Authority of India
➜ The People’s Bank of China
➜ The Reserve Bank of India
➜ U.S. Securities and Exchange Commission
➜ World Economic Forum
➜ World Trade Organization
Public consultations
GLEIF actively participates in relevant
public consultations published by
regulators and organizations to
highlight the added value of the LEI.
GLEIF prioritizes this activity to raise
awareness of the LEI and further
drive its global use. In 2022, GLEIF
responded to 53 consultations
across 7 jurisdictions.
Proposed future LEI use includes the following:
US
Financial Data
Transparency
Act
US Customs
and Border
Protection
Global Business
Identifier
Open
Finance
Alternative
Investment
Funds
2022 Annual Report
7
GLEIF’s strategic focus in 2022 was guided by
the organization’s vision: for the LEI to enable
one global identity behind every business.
Efforts continued to broaden the relevance
and utility of the LEI and to bring new value to
existing and additional public and private sector
stakeholders. This led to a tangible acceleration
in interest, advocacy, and use of the LEI across
new markets and applications, reflecting the
success of GLEIF’s commitment to bring
LEI-associated benefits to all.
Opening doors for
LEI use in new fields
GLEIF celebrated a surge of interest in the LEI across
a wide range of new public and private sector use
cases and applications in 2022. Growing acceptance was
stimulated throughout the year by strong advocacy
from some high-profile LEI champions.
Cross-border payments
• In 2022, the FSB published
a report encouraging
global standards-setting
bodies and international
organizations with
authority in the financial, banking, and payments space
to drive forward LEI references in their work. A primary
near-term goal of the FSB’s report, published as part of
the G20 Roadmap for Enhancing Cross-Border Payments,
is to accelerate LEI use initially in cross-border payment
transactions. By helping to make these transactions
faster, cheaper, more transparent, and more inclusive,
while maintaining their safety and security, the LEI has
been deemed by the FSB to support the goals of the G20
roadmap.
Trade finance and supply chain
• The EC’s Expert Group on the
European Financial Data Space
issued a Report on Open Finance,
which stated that the LEI has an
important role to play in open finance
by promoting standardized data
identification and aggregation, improving data quality and
transparency, and reducing costs related to verification
checks. The Expert Group recognized the value that the
LEI brings to enabling meaningful data sharing through
standardization and harmonization and the role the
LEI plays in facilitating identification of financial service
providers and other legal entity parties in a seamless
way through the publicly accessible Global LEI Index.
The Expert Group also highlighted the LEI’s utility for
streamlining the acquisition of trade financing process
for all businesses, and for small and mid-size enterprises in
particular.
• Reinforcing the support of the EC, the
BIS published a paper recognizing the
need for corporate digital identity
based on a unique legal entity identifier
to promote operational efficiency,
market integrity, and financial stability and inclusion. The
BIS proposed that the LEI is a ‘sounder starting point’ for
corporate ID than business registration identifiers, as it is
global, unique, and widely recognized.
• In a whitepaper entitled ‘Shutting
Fraudsters Out of Trade’, the ICC
called for the use of the LEI, alongside
digital ledgers, invoice number
tracking, and Application Programming
Interfaces (APIs) between revenue departments, banks,
and regulators, to enable banks to share fraud data
and help shut fraudsters out of the system. The ICC also
recommended that organizations become Validation
Agents in the Global LEI System to ensure that their
clients engaged in cross-border payments obtain an
LEI to help to prevent fraud related to misidentification
in financial transactions.
• In early 2022, GLEIF partnered with Surecomp to embed
the Global LEI Index into RIVO, its cloud-based trade
finance solution. Incorporating LEI data enables Surecomp
customers to verify the identity of trade participants
quickly, facilitating greater trust and transparency within
trade transactions and standardizing entity identification
for better Know Your Customer (KYC), fraud, and Anti-
Money Laundering (AML) compliance.
What is the Global LEI System?
The Global LEI System is the infrastructure that
enables LEIs to be issued to legal entities globally.
The Global LEI System operates in three-tiers:
•
The ROC is a group of more than 65 financial
market regulators and other public authorities
and 19 observers from more than 50 countries. It
promotes the broad public interest by improving
the quality of data used in financial data reporting,
improving the ability to monitor financial risk,
and lowering regulatory reporting costs through
the harmonization of these standards across
jurisdictions. It oversees GLEIF to ensure it upholds
the principles of the Global LEI System.
•
GLEIF supports the implementation and use of the
LEI. It makes available the Global LEI Index which
is the only global online source that provides open,
standardized and high quality legal entity reference
data. It also provides services that ensure the
operational integrity of the Global LEI System, such
as the accreditation of LEI issuing organizations.
•
LEI issuing organizations are accredited by GLEIF to
supply registration, renewal, and other services, and
act as the primary interface for legal entities wishing
to obtain an LEI.
2022 Annual Report
8
Strategic Priorities:
Pushing New Boundaries
in Identity Management
ESG reporting
GLEIF strongly advocates the availability and usage of the
LEI to support transparency in global sustainability initiatives.
In line with the global business community’s growing
commitment to ESG goals, GLEIF promotes the role that the
LEI can play in standardizing entity identification for ESG data
comparison. By tagging entities with the LEI and using it as an
ESG data connector, transparency can be increased for the
reporting entity, related companies, and even for suppliers.
Inclusion of the LEI in ESG tagging will ultimately facilitate
enhanced comparability of ESG data during due diligence
and KYC processes.
• In 2022, OS-Climate, hosted by
the Linux Foundation, welcomed
GLEIF’s participation in a
collaborative effort to drive trust
and transparency with its Open-Source Climate Data and
Analytics Solutions. As an active contributor to this open-
source community, GLEIF will help realize OS-Climate’s
goal of building a data and software platform that boosts
global capital flows into climate change mitigation and
resilience.
• The value of the LEI in supporting the
G20’s sustainability agenda was also
recognized in a report published by
leading global business community
influencers – the Business Twenty
(B20), Business in the Organization
for Economic Co-operation and
Development (OECD), and the
International Organisation of
Employers (IoE). The LEI is recognized for its
capacity to reduce costs and fragmented
approaches across borders for the business
community and help set the stage for better
risk management information in the future.
• GLEIF was also confirmed as
co-lead of the ‘discoverable
data’ subgroup for The
Carbon Call. The Carbon Call
builds on, promotes, and
helps accelerate ongoing work to improve measurement,
reporting, and verification of greenhouse gas (GHG)
emissions and removal, primarily for the corporate
sector. The LEI and the vLEI can play a crucial role in
sustainability reporting frameworks and, as the co-lead of
the ‘discoverable data’ subgroup, GLEIF can help promote
transparency in sustainability reporting to support The
Carbon Call roadmap released at COP27.
The vLEI: A bedrock for
cross-border digital trust
A cornerstone of GLEIF’s strategic focus in 2022 was the
continued expansion of the Global LEI System to create
a wholly unique, cross-border digital trust ecosystem that
can verify the identity of a legal organization or a person
acting on its behalf. The organization set a rapid pace in
its continued development of the vLEI infrastructure – the
implementation backbone that will enable digitally verifiable
versions of the LEI to bring trust and transparency to any
and all digital organizational identity management systems
in the future.
Notable advances were made on this front in 2022 with
significant milestones realized.
• GLEIF published its vLEI Ecosystem Governance
Framework, which defined the vLEI operational model and
described how vLEI issuing organizations would be qualified
and perform their roles. The Framework was created in
full accordance with standards and recommendations
of the Trust Over IP Foundation (ToIP), hosted by the
Linux Foundation, and it was the most comprehensive
framework ever developed using the ToIP Governance
Metamodel. The publication of the Framework represented
a foundational step for the vLEI initiative.
• A new International Organization for Standardization (ISO)
standard was published, supporting the uniform inclusion
of ‘official organizational roles’ in LEI-based digital identity
tools. The significance of ISO 5009 was its capacity to pave
the way for vLEI credentials and digital certificates with
embedded LEIs to become a universally trusted method of
digitally confirming the authenticity of people authorized
to act on behalf of an organization. The combination of
LEIs and official organizational roles within digital identity
credentials promotes greater trust in the authenticity of
an entity’s authorized representatives, enabling new digital
identity management use cases.
• GLEIF launched the verifiable LEI Issuer Qualification
Program, enabling organizations to become qualified by
GLEIF to act as the primary interface for legal entities
seeking vLEI credentials.
• GLEIF qualified the first vLEI issuer. Provenant’s
qualification was accompanied with an announcement
that the organization was trialling a suite of
organizational identity services designed to leverage the
vLEI. The suite of services, comprising credential and key
management, digital signing, and verification, was being
offered for proof-of-concept trials to organizations in the
business telecoms ecosystem.
The significant progress and irreversible momentum already
achieved indicate an exciting outlook for 2023 and beyond.
As an increasing number of vLEI issuers become qualified,
more industry-specific use cases and services that utilize the
vLEI will emerge.
2022 Annual Report
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