About LEI Common Data File Formats

Level 2 Data: Reporting Exceptions Format



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.

GLEIF published the document ‘Reporting Exceptions Format’ version 1.0 in November 2016 for information. In May 2017, GLEIF published a further update: Reporting Exceptions format version 1.1. The detailed technical specification document and the corresponding XML schema definition are available for download at the foot of this page. Changes introduced in version 1.1, compared to the Reporting Exceptions format version 1.0, are minor and backwards compatible. These changes are detailed in section 1.7 (‘Release Notes’) of the technical specification document available below.

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 its policy paper, titled ‘Collecting data on direct and ultimate parents of legal entities in the Global LEI System – Phase 1’, the LEI Regulatory Oversight Committee (LEI ROC), defines the option to decline providing parent information for the reasons listed in section 3.3.1 of the LEI ROC’s paper.

Section 3.3.1 states, among other things, that the LEI ROC considers that there should only be the following limited list of reasons for an entity to decline providing information on its parents, knowing that the adequacy of the list will be reviewed by the LEI ROC “as needed in light of experience”:

  • There is no parent according to the definition used: this will include for instance (i) the entity is controlled by natural person(s) without any intermediate legal entity meeting the definition of parent in the Global LEI System; (ii) the entity is controlled by legal entities not subject to preparing consolidated financial statements (given the definition of parents in the Global LEI System); (iii) there is no known person controlling the entity (e.g., diversified shareholding).
  • Legal obstacles prevent providing or publishing this information: this will include (i) obstacles in the laws or regulations of a jurisdiction; (ii) other binding legal commitments such as articles governing the legal entity or a contract.
  • 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.

The diagram below shows the structure of the Reporting Exceptions format, 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
  • NO_KNOWN_PERSON
  • LEGAL_OBSTACLES
  • BINDING_LEGAL_COMMITMENTS
  • DETRIMENT_NOT_EXCLUDED
  • DISCLOSURE_DETRIMENTAL
[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 Format

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


Relevant Files for Download