About LEI Common Data File Formats

Level 2 Data: Reporting Exceptions Format 2.1



The Legal Entity Identifier (LEI) data pool includes ‘Level 2’ data to answer the question of ‘who owns whom’. Specifically, legal entities that have or acquire an LEI report their ‘direct accounting consolidating parent’ as well as their ‘ultimate accounting consolidating parent’.

Records in the Reporting Exceptions format refer to a child legal entity and its direct or ultimate parent and mention the type of reporting exception. Reporting exceptions are:

  • There is no parent entity.
  • The child legal entity opts out of reporting for exceptional reasons (see below).
  • Parent entities do not have an LEI.

In November 2016, GLEIF published the initial Reporting Exceptions Format version 1.0. In May 2017, GLEIF published Reporting Exceptions format version 1.1, and in September 2021, Reporting Exceptions format version 2.1. Compared to the Reporting Exceptions format version 1.1, the version 2.1 introduces the addition of a new exception reason, ‘NON_PUBLIC’. The corresponding XML schema definition and the Release Notes document are available for download at the foot of this page.

The GLEIF Concatenated Files, which are available for download, include specific information on an LEI record and related reference data based on the relevant reporting format. Reporting exceptions are detailed in the Level 2 Reporting Exceptions Concatenated File.

In the policy paper, titled “PNI data collection and opt-outs to parent relationship reporting Revision of ROC policies related to the Level 2 parent relationship data”, the Regulatory Oversight Committee (ROC), defines the list of acceptable reasons for legal entities to opt- out from the provision of information on direct and ultimate parent LEIs (from now on referred to as the list of opt-outs). The goal of the revision is to consolidate them in a way that facilitates the best use of the opt-outs while at the same time retaining the most valuable/most used information.

The previously existing nine opt-out reasons can be summarized in three broad categories:

  • Non-consolidating, whenever the accounting consolidation definition for parent relationship does not apply. This category includes cases where the entity is controlled by a natural person(s) without any intermediate legal entity (“Natural Person(s)”); the entity is controlled by legal entities not subject to consolidation (“Non-Consolidating”); and where there is no known person(s) controlling the entity (“No Known Person” e.g.; the entity is controlled by diverse shareholders).

  • Non-Public, whenever the relationship information is non-public and therefore creates obstacles to releasing this information. This category includes cases where there are obstacles in the laws or regulations of a jurisdiction restricting the reporting (“Binding Legal Constraint”); the existence of other legal constraints such as articles governing the legal entity or a contract (“Legal Obstacles”); where disclosure of the information would be detrimental to the legal entity or the relevant parent (“Disclosure Detrimental” and “Detriment Not Excluded”); and where the consent to disclose the parent LEI was not obtained (“Consent Not Obtained”). An entity is not required to provide non-public relationship information in order to register or renew an LEI.

  • No LEI, when the parent does not consent to obtain an LEI or to authorize its “child entity” to obtain an LEI on its behalf.

The diagram below shows the structure of the Reporting Exceptions format 2.1, including definitions of the data content to be provided.

ReportingExceptionData
Header [1,1]
ContentDate The date and time as of which the data contained in the file is valid. repex:LEIDateTimeProfile A date and time, including the timezone, based on ISO 8601. [1,1]
Originator The LEI of the entity that created the content of this file. repex:LEIType A Legal Entity Identifier (LEI) code, conforming to ISO 17442. [0,1]
FileContent A code describing the content of this Reporting Exceptions file. repex:FileContentEnum Codes denoting the publisher of the Reporting Exceptions file (GLEIF or LEI Issuer / LOU), the publication status (public or internal use) and the content type (full file, delta file or query response).
A value of type FileContentEnum in a file conforming to this standard SHALL be one of the following code strings:
  • LOU_FULL_PUBLISHED
  • LOU_DELTA_PUBLISHED
  • GLEIF_FULL_PUBLISHED
  • GLEIF_DELTA_PUBLISHED
  • QUERY_RESPONSE
[1,1]
DeltaStart The date and time of the baseline relative to which this file contains new or changed Reporting Exceptions. repex:LEIDateTimeProfile A date and time, including the timezone, based on ISO 8601. [0,1]
RecordCount The number of Reporting Exceptions (RepEx) in the file. Must be a positive whole (integer) number, or zero (0). xs:nonNegativeInteger A positive whole number or zero (0). [1,1]
Extension This Extension element contains any additional elements required to extend the Header container element. repex:ExtensionType Data element(s) defined by the sender of the file. A description of Extension element structure and content should be provided separately. [0,1]
ReportingExceptions [1,1]
Exception [1,1]
LEI The ISO 17442 compatible identifier for the legal entity which raised this exception. repex:LEIType A Legal Entity Identifier (LEI) code, conforming to ISO 17442. [1,1]
ExceptionCategory A category of mandatory information reporting, beyond the minimum required for legal entity identification, which the legal entity declines, giving reasons and references where applicable. repex:ExceptionCategoryEnum A value of type ExceptionCategoryEnum in a file conforming to this standard SHALL be one of the following code strings:
  • DIRECT_ACCOUNTING_CONSOLIDATION_PARENT - The legal entity has declined to report a direct accounting consolidation parent, based on applicable accounting standards.
  • ULTIMATE_ACCOUNTING_CONSOLIDATION_PARENT - The legal entity has declined to report an ultimate accounting consolidation parent, based on applicable accounting standards.
[1,1]
ExceptionReason A single reason provided by the legal entity for declining to provide the mandatory report of a specified type of information (beyond the minimum reference data needed purely for identification of the legal entity). repex:ExceptionReasonEnum A value of type ExceptionReasonEnum in a file conforming to this standard SHALL be one of the following code strings:
  • NO_LEI
  • NATURAL_PERSONS
  • NON_CONSOLIDATING
  • deprecated BINDING_LEGAL_COMMITMENTS
  • deprecated LEGAL_OBSTACLES
  • deprecated DISCLOSURE_DETRIMENTAL
  • deprecated DETRIMENT_NOT_EXCLUDED
  • deprecated CONSENT_NOT_OBTAINED
  • new NON_PUBLIC
Note: The reporting exception reason categories BINDING_LEGAL_COMMITMENTS, LEGAL_OBSTACLES, DISCLOSURE_DETRIMENTAL, DETRIMENT_NOT_EXCLUDED and CONSENT_NOT_OBTAINED are retained for technical compatibility but will be considered deprecated from March 1, 2022 onwards. These exception reasons will be consolidated to the newly added Exception ReasonEnum(NON_PUBLIC) from March 1, 2022.
[1,*]
ExceptionReference References of the law, regulation or other element of the legal framework to support reason(s) provided by the legal entity for declining to provide information on its parents. repex:Tokenized500Type An element of this type has minimum length of one character and may not contain any of: the carriage return (#xD), line feed (#xA) nor tab (#x9) characters, shall not begin or end with a space (#x20) character, or a sequence of two or more adjacent space characters. [0,*]
Extension This repex:Extension element may contain any additional elements required to extend the Reporting Exception. repex:ExtensionType Data element(s) defined by the sender of the file. A description of Extension element structure and content should be provided separately. [0,1]

Reporting Exceptions 2.1 Format

Note: The new enumeration values added in the Reporting Exceptions format version 2.1 are highlighted in yellow. Likewise, the deprecated enumeration values are maintained for technical backward compatibility.

For technical documents and example files required for upgrading to the current versions, please see the Supporting Documents page.

Please address questions on the Reporting Exceptions format to info@gleif.org.


Relevant Files for Download

• The Release Notes for the Reporting exceptions format version 2.1: reporting_exceptions_format_version_2.1–documentation.html
• The corresponding XML schema definition: 2021-07-20_reporting-exceptions-format-v2-1.xsd
• Download as PDF: State Transition and Validation Rules for Common Data File Formats (Version 2.6)