Clients must have LEI from 3 July

The Markets in Financial Instruments Regulation (MiFIR), which was effective on 3 January 2018, requires all firms subject to MiFIR transaction reporting obligations or that are a UK branch of a third country firm to obtain an LEI from their clients before executing a transaction in a financial instrument subject to the MiFIR transaction reporting obligations. The LEI must be included in the investment firm’s transaction report. As a result of delays in entities obtaining LEIs, on 20 December 2017, ESMA issued a 6-month form of reprieve. Today, ESMA confirms there is a significant increase in the number of LEIs obtained; therefore it will not be extending that reprieve beyond 3 July. In practice, this means that investment firms must ensure that a client which is a legal entity or structure must have an LEI code to continue to act on its instructions or make a decision to trade on its behalf from 3 July 2018 onwards.