LEI Data Access and Use LEI Data

ROC Policy on Level 1 Data



The Regulatory Oversight Committee (ROC) published a policy on March 28, 2018 related to Legal Entity Events, entitled ‘Legal Entity Events (formerly referred to as “Corporate Actions”) and Data History in the Global LEI System’, which describes events that alter the entity, the relationship data of a legal entity, or result in the retirement and/or creation of LEIs. Detailed information about this policy is available for download on this page.

In December 2020, the ROC published a policy entitled ‘LEI Eligibility for General Government Entities Guidance Document’, which describes how certain legal entities are classified as Government Entities or International Organizations. Detailed information about this policy is available for download on this page.


Legal Entity Events (formerly referred to as “Corporate Actions”) and Data History in the Global LEI System

The main features of the ROC document are summarized as follows in the report:

  • A change in terminology to refer to the events to be captured in the reference and relationship data in the GLEIS as “legal entity events” rather than corporate actions.
  • An incremental approach to implementation of capturing legal entity events that would prioritize those events that occur relatively frequently and directly affect the Level 1 and Level 2 reference data (e.g., name changes, mergers, and acquisitions), and place a lower implementation priority on those events that occur relatively infrequently (e.g., reverse takeover). Such an iterative, phased approach is more desirable, as there are too many theoretical scenarios and unintended consequences to fully envision prior to implementation.
  • Commercial or regulatory data feeds should be incorporated into the GLEIS to notify LOUs of potential changes to entities under their maintenance resulting from legal entity events and to elicit updates to LEI records by the affected entities (through the normal process of self-registration). In the case of inactive entities, data feeds could also be used to update the records without the entity’s consent, in line with existing ROC policies and GLEIF technical standards.
  • Effective dates should be incorporated into the GLEIS. Effective dates reflect when legal entity events become legally effective in addition to the current requirement of recording when they are introduced to the GLEIS.
  • Users should be able to easily access and use an entity’s data history through multiple channels (e.g., whether they are using a user interface, an application programming interface, or downloadable files).
  • Complex acquisitions will reflect as accurately as possible the chain of legal events as reflected in the official registries of the relevant jurisdictions, in line with existing GLEIS principles of corroborating GLEIS records with official sources.
  • Spin-off relationships will be recorded in the GLEIS on a fully optional basis, with possible mandatory reporting at a future date to be determined by the ROC.
  • The definition of inactive entities should be clarified to adequately capture entities that are still legally in existence but have no operations.
  • A number of publicly and non-publicly available sources may be used for data validation, including financial statements, other documents supporting the preparation of consolidated financial statements, regulatory filings, and other sources such as third- party data vendors.

LEI Eligibility for General Government Entities

The main feature of the ROC document are summarized as follows in the report:

  • ROC proposes to specifically identify Government entities in the GLEIS. This is done by creating two new “entity category” types in addition to existing entity category types, which are currently “FUND”, “BRANCH”, “SOLE _PROPRIETOR”.
  • The new entity category types are “RESIDENT GOVERNMENT ENTITY” and “INTERNATIONAL ORGANIZATION”.

Relevant Files for Download