Global Legal Entity Identifier Foundation
GLEIF
The Global Legal Entity Identifier Foundation supports global identification systems for legal entities.
Lobbying Activity
Response to Revision of EU rules on the eInvoicing
12 Dec 2025
The Global Legal Entity Identifier Foundation (GLEIF) welcomes the European Commissions initiative to review the EU rules on electronic invoicing in public procurement. Public procurement is a cornerstone of the Single Market, underpinning transparency, competition, and innovation. As the Commission seeks to strengthen competitiveness and reduce administrative burdens, greater harmonization and interoperability of e-invoicing systems are essential. Despite progress, e-invoicing in the EU continues to face challenges: fragmented standards, limited interoperability between systems, and insufficient use of trusted digital identifiers. These issues lead to transparency gaps, reconciliation delays, and heightened fraud risks. The forthcoming revision presents an important opportunity to address these shortcomings by integrating globally recognized identification standards into the EU framework. The ISO 17442 Legal Entity Identifier (LEI) and its verifiable counterpart (vLEI) provide a unique, globally recognized digital identity for legal entities. The LEI is a 20-character alphanumeric code linked to authoritative, verified reference data, maintained as a public good by GLEIF under the oversight of regulators worldwide, including the European Commission. Its use in e-invoicing would deliver substantial benefits. First, the LEI ensures consistent and reliable identification across borders and systems. It complements the European standard on eInvoicing (EN 16931) and supports the Commissions objective of full interoperabilitytechnical, semantic, and organizational. By uniquely identifying counterparties, the LEI reduces impersonation risks and strengthens the integrity of procurement and payment chains. Second, a single global identifier simplifies compliance. Businesses today must manage multiple national identifiers, which differ in format, governance, and availability. Using the LEI as a universal identifier would lower administrative costs, reduce the complexity of cross-border procurement, and remove technical barriers for companies operating in multiple Member States. Moreover, the LEIs cross-border applicability has been validated in practice. GLEIFs JapanEU eSeal proof-of-concept demonstrated that embedding the LEI in trust services enables mutual verification of sealed e-invoices and other documents across jurisdictions, supporting the G20 Data Free Flow with Trust (DFFT) principle and showing how the LEI can serve as a global trust anchor. Additionally, the LEI aligns with the VAT in the Digital Age (ViDA) package and facilitates automated VAT and sustainability reporting by linking invoices to verified legal entities. The vLEI further enables cryptographically secure, machine-to-machine interactions, eliminating manual name-matching and supporting the Commissions digital transition objectives. Finally, making the LEI a mandatory unique identifier for both debtor and creditor entities in e-invoices and related payment messages would create a secure, transparent, and traceable end-to-end payment chain. The LEI complements BICswhich route paymentsby reliably identifying the parties involved. GLEIFs free, public API enables real-time validation of LEIs and their linkage to BICs, providing a trusted and consistent source of truth for all stakeholders. By incorporating the LEI and vLEI into the revised EU e-invoicing rules, the EU can future-proof its framework, reduce fragmentation, and unlock the full potential of digitalization in public procurement. This approach advances interoperability, innovation, and competitivenesscore objectives of the Commissions strategy for a stronger and more resilient Single Market.
Read full responseMeeting with René Repasi (Member of the European Parliament, Rapporteur) and Fleishman-Hillard
9 Oct 2025 · 28th Regime
Response to Digital services for simplifying business operations and reducing administrative costs – the business wallet
12 Jun 2025
The Global Legal Entity Identifier Foundation (GLEIF) welcomes the European Commissions initiative to develop the European Business Wallet (EBW) as part of its broader digital transformation agenda. GLEIF supports the creation of a trusted, standardised, and interoperable digital identity infrastructure for legal entities across the EU and recommends integrating the Legal Entity Identifier (LEI) and the verifiable LEI (vLEI) into the EBW framework. Currently, the fragmentation of national portals and inconsistent identification practices across Member States create significant barriers to simple and fully digital cross-border business. The LEIa globally recognized, ISO 17442-compliant identifiercan address this fragmentation by providing a unique, persistent, and interoperable identification solution. Its use would facilitate cross-border transactions, reduce administrative burdens, and support regulatory compliance. The LEI is already mandated or referenced in multiple EU regulations, including eIDAS1, eIDAS2, and Implementing Regulation (EU) 2024/2977. GLEIF maintains the LEI system in the public interest under the oversight of the Regulatory Oversight Committee (ROC), which includes the European Commission. LEI data is openly available via public APIs, enabling seamless integration into digital business processes such as onboarding, Know-Your-Customer (KYC) procedures, and regulatory reporting. The vLEI builds upon the LEI system by offering cryptographically verifiable credentials that link a legal entity to its authorised representatives. This supports role-based delegation, revocation, and real-time governancefeatures essential for secure digital operations. GLEIF believes that integrating the vLEI into the EBW would enable support for complex organisational workflows such as regulatory filings, procurement, and ESG reporting. Key requirements for the EBW and supporting ecosystem that GLEIF highlights include: Standardised Legal Entity Identification: The LEI ensures a consistent, global identifier decoupled from national registry constraints. Role-Based Delegation and Revocation: vLEI credentials support secure delegation and dynamic updates to reflect real-time organisational changes. Layered and Modular Credentialing: The system must accommodate linked credentials (e.g., tax ID, registry extract, role delegation) for complex scenarios like AML compliance or digital product verification. PublicPrivate Governance: The federated LEI model aligns with EU digital sovereignty and innovation goals through a network of accredited LOUs. Global Interoperability: The LEIs alignment with global standards (FATF, ISO 20022, OECD BEPS) supports legal and technical interoperability beyond EU borders. Automation and Digital Agency: LEI and vLEI enable scalable automation of verification, contract execution, and digital service delivery. Beyond technical integration, GLEIF urges support for an EBW ecosystem that: Enables selective and context-aware data disclosure using technologies such as Zero Knowledge Proofs. Supports multiple credential and data issuers including governments, corporations, and automated agents. Encourages the development of a modular, sustainable digital wallet economy with diverse custodial models and commercial services. Facilitates cryptographically signed, machine-readable Ricardian contracts for legal enforceability. Accounts for machine identity and delegation, especially in contexts involving smart contracts and AI agents. GLEIF recommends the LEI be adopted as foundational component of the EBW. Its inclusion would enhance regulatory alignment, promote cross-border business, and support a secure and future-proof digital identity infrastructure in line with the EUs strategic objectives. GLEIF remains available to support the Commissions work and welcomes further dialogue on the role of LEI and vLEI in the EBW framework.
Read full responseGLEIF urges EU to adopt global identifiers in procurement
7 Mar 2025
Message — The organization proposes using the ISO 17442 Legal Entity Identifier to help identify companies during the bidding process. They recommend allowing public authorities to require this identifier in early information notices. They also call for rules ensuring these identifiers follow international oversight standards to keep data accurate.123
Response to Savings and Investments Union
7 Mar 2025
As the European Union (EU) advances its plans for a Savings and Investments Union (SIU), the Global Legal Entity Identifier Foundation (GLEIF) strongly believes that the Legal Entity Identifier (LEI) can play a critical role in removing barriers to cross-border investment and strengthening the efficiency, security, and transparency of EU capital markets. The LEI is a globally recognised 20-character, alpha-numeric code based on the ISO 17442 standard already largely used within the EU capital market. It provides a unique and verifiable identity for legal entities engaged in financial transactions, enabling transparency and risk mitigation. As a public good maintained by GLEIF on behalf of the Regulatory Oversight Committee (ROC)which includes the European CommissionLEI data is freely available, machine-readable, and integrates seamlessly into digital financial processes. One of the persistent challenges in the EU is the fragmentation of capital markets due to inconsistent legal entity identification across Member States. The lack of standardised procedures for identifying investors and companies results in inefficiencies, delays, and increased compliance burdens, limiting the smooth flow of capital across borders. By providing a universal and standardised identifier, the LEI can address these inefficiencies by: - Enhancing Market Transparency: A standardised LEI system would allow investors and regulators to track entities raising capital across jurisdictions, ensuring a consistent and reliable identification mechanism for compliance and reporting. - Facilitating Cross-Border Investments: The LEI eliminates ambiguity caused by multiple identifiers across jurisdictions, allowing investors to easily verify corporate identities and their affiliations (e.g., parent and subsidiary relationships). - Supporting Digitalisation & Automation: Given that LEI data is openly accessible via APIs, it can be integrated into automated processes, supporting the digitalisation of capital markets, streamlining KYC and AML checks, and reducing friction in investment transactions. - Strengthening Trust in Capital Markets: A universally recognised legal identity framework enhances investor confidence by ensuring that both domestic and foreign investors can trust the entities they engage with. Furthermore, with the rise of smart contracts and digital assets, the verifiable LEI (vLEI) can be embedded in digital asset metadata, offering a tamper-proof mechanism to authenticate the legal entity behind financial instruments. This innovation aligns with the EUs vision for secure, digitalised capital markets. In summary, integrating the LEI into the SIU framework would contribute to harmonising regulatory identification standards across Member States, reducing market fragmentation, and making EU capital markets more accessible, efficient, and attractive for global investors. By leveraging the LEIs existing infrastructure, the EU can accelerate progress toward a more unified, resilient, and digitally advanced financial ecosystem.
Read full responseMeeting with Eero Heinäluoma (Member of the European Parliament)
12 Sept 2024 · Current Affairs
Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)
12 Jul 2024 · LEI/EUID - DORA
Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament, Shadow rapporteur) and Fleishman-Hillard and Council of Bars and Law Societies of Europe
4 Sept 2023 · Upgrading Digital Company Law
Response to Evaluation of EU Directive on electronic invoicing in public procurement & Communication for EP and Council
14 Apr 2023
The Global Legal Entity Identifier Foundation (GLEIF) is pleased to provide comments to the European Commission Call for Evidence for the Public procurement EU rules on electronic invoicing in public procurement. GLEIF will focus its comments on how leveraging the Legal Entity Identifier (LEI), a machine-readable digital standard for entity identification within the semantics of the European standard on eInvoicing, can help to address cross-border and transnational frictions and simplify business processes of economic operators when supplying goods, works and services to a public administration. GLEIF suggests that fragmentation of data space and single market for data among the Member States is a major risk for creating an EU fit for digital age and digital transformation. This fragmentation affects the usability of data and the value generation through data, which also impacts the braoder use of the eInvoices by the economic operators. While GLEIF welcomes the European Commissions call for evidence to review the effects of the Directive on the single market and on the uptake of eInvoicing in public procurement and promote digital integration between businesses within the digital single market, GLEIF would like to emphasize that the usability of data will depend on its interoperability and standardization. When it comes to these two fundamental principles, GLEIF suggests that a critical question for EU authorities will be how to securely standardize the identification of entities looking to access/share data from/with other entities. A role for public authorities in that standardization is needed. The report on shaping the digital transformation in Europe highlights a lack of common standards for data and interoperability contributes to a lag in next-generation digital infrastructure. Secondly, regulation pertaining to the digital sector is not fully harmonized across the Member States (especially for emerging, high-impact technologies), which risks hindering the Digital Single Market in the EU. Adding the LEI in the core data set of the semantics of the European standard for eInvoicing will boost interoperability within the Digital Single Market. Whenever the question of identifying securely a third party arises, the LEI plays a useful role as EU authorities reflect on their future data strategy. The LEI, as a global ISO standard (ISO 17442) for unique, unambiguous legal entity identification, offers a supra-sectoral and supra-EU solution. It also ensures interoperability across member states as well as firms participating in EU solutions from third countries given the EU prides itself on the openness of its public procurement market. The EU-wide publication of tenders creates opportunities for companies across the EU and the world. Third country bidders can be easily and unambiguously identified if the LEI is added as a mandatory data element within the semantics of the European standard for eInvoicing. As a universally unique identifier based on an international standard, the LEI can be considered a relevant attribute in many applications where authenticated transactions are relevant. LEI is a quality-controlled unique identifier supported by a transparent infrastructure of local identity validation and a centralized open data challenge service and provides standardized reference data, which shows any eligible entity in a network of ownership and other relationships. The LEI is already included on the EU Electronic Address Scheme (EAS) code list. Please see attached GLEIF's full response.
Read full responseResponse to Facilitating small and medium sized enterprises’ access to capital
28 Mar 2023
The Global Legal Entity Identifier Foundation (GLEIF) is pleased to provide comments on the European Commission proposed Listing Act package, which is a welcomed initiative to improve the attractiveness of EU capital markets. GLEIF believes that, as part of the Listing Act package, reopening the Prospectus Regulation is an opportunity to mandate the annual renewal of issuers ISO 17442 Legal Entity Identifiers (LEIs). According to Art. 7(4) of the Prospectus Regulation, issuers are required to include their LEI in the prospectus summary relating to securities offered to the public and/or admitted to trading on an EU regulated market. However, the Prospectus Regulation does not require LEI renewals for these issuers. GLEIF believes that there is a strong case to mandate the annual renewal of issuers LEI in the reviewed Prospectus Regulation. In order to maintain its validity, the LEI must be renewed at least annually. Renewing an LEI means that its reference data namely, the publicly available information on legal entities identifiable with an LEI is re-validated by the managing LEI issuer against a third party source. LEI issuing organisations (Local Operating Units) are responsible for this process, alongside LEI supply registration and other services. The annual renewal of issuers LEIs is indeed crucial to ensure that investors have continuous access to high-quality and trustworthy and up-to-date data on issuers, as well as for issuers to avoid the risk of administrative sanctions for non-compliance due to lapsed (i.e. not renewed) LEIs. Mandating LEI renewals in the Prospectus Regulation i.e.: for those issuers that are already required to disclose their LEI in prospectus summaries would secure the goals described above. Furthermore, it would serve the broader goals of the Prospectus Regulation in terms of transparency, and of the Listing Act package in terms of fostering the attractiveness of EU capital markets. Background on the LEI and GLEIF The LEI is a 20-character, alpha-numeric code, based on the ISO 17442 standard, is used for uniquely and unambiguously identifying legal entities globally. Each LEI contains information about an entity's ownership structure and thus answers the questions of 'who is who' and 'who owns whom'. Simply put, the publicly available LEI data pool can be regarded as a global directory, which greatly enhances transparency in the global marketplace. The Global Legal Entity Identifier Foundation (GLEIF) is the not-for-profit foundation that manages the ISO 17442 Legal Entity Identifier (LEI).
Read full responseMeeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur) and France Digitale
29 Sept 2022 · Data Act
Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur)
23 Jun 2022 · European Digital Identity proposal (eID)
GLEIF urges EU to mandate global identifiers for supply chains
19 Jun 2022
Message — GLEIF recommends mandating the Legal Entity Identifier to standardize due diligence and transparency across Member States. They suggest requiring companies to use standardized data templates to report and monitor their global suppliers.12
Why — Mandating this identifier would cement GLEIF's system as the universal standard for supply chain transparency.3
Impact — Opaque businesses and subcontractors lose their ability to hide within complex supply chains.4
Response to Environmental, social and governance (ESG) ratings and sustainability risks in credit ratings
1 Jun 2022
The Global Legal Entity Identifier Foundation (GLEIF) is pleased to provide comments to the European Commission's Initiative titled ESG ratings and sustainability risks in credit ratings. GLEIF will focus its comments on using the Legal Entity Identifier (LEI) as a data element in ESG reporting to increase ESG rating transparency at the entity level and facilitate comparability of ESG data exchange.
A key challenge in ESG reporting, data collection and data exchanges today is the lack of standardization for entity identification. This makes it difficult to find, compare and consume ESG data globally – leading to a lack of transparency and inefficiencies. Without a clear, standardized and global entity identification system ESG reports lose value as it is not easy to evaluate performance indicators across different reporting regimes or jurisdictions. There are innumerable national and regional standards for entity identification across the world and while different identifiers serve national needs, they can create significant conflicts and inefficiencies when reconciling data across geographical borders. And these geographical borders could apply to the movement of goods and services or company structures.
GLEIF welcomes the Commission’s study on the transparency around data sourcing and methodologies of ESG ratings. Starting ESG data collection with a holistic entity identification approach via is the foundational step to achieve transparency at the entity level. Without ensuring transparency at the entity level, it is not possible to achieve the timeliness, accuracy and reliability of ESG ratings. Moreover, it is also equally important to know from a supervisory point of view, who the rating provider company is, thereby, supervisors can analyze any potential conflicts of interest and mitigate any associated risks.
Please see GLEIF's full response attached.
Read full responseResponse to Fighting the use of shell entities and arrangements for tax purposes
6 Apr 2022
The Global Legal Entity Identifier Foundation (GLEIF) is pleased to provide comments to the European Commission Inception Impact Assessment titled Fighting the Use of Shell Entities and Arrangements for Tax Purposes.
GLEIF welcomes the European Commission’s initiative to ensure fair and effective taxation in the EU by combatting tax abuse and aggressive tax planning of shell entities. GLEIF will focus its comments on how the inclusion of the Legal Entity Identifier (LEI) in tax schemes and information exchange modalities across supervisory authorities can enhance transparency on shell entities.
GLEIF suggests that, in parallel to the discussions on the recent global minimum tax rate decision, the unique and unambiguous identification of (i) the subsidiaries of multinational companies, and (ii) paying entities became more important and urgent. Currently, in the Global LEI System, although most of the multinationals have an LEI, not all of these entities are reporting the LEI of their subsidiaries. The LEI can uniquely and unambiguously identify all subsidiaries in a group structure. It can then be leveraged to identify the producer, intermediary and distributor entities of a group to better understand transaction data such as buy & sell relationships. This is similar to the approach followed by the Commission when implementing transaction reporting requirements involving the LEI for the Markets in Financial Instruments Directive II (MiFID II)/Markets in Financial Instruments Regulation (MiFIR). Furthermore, the Banque de France demonstrates how the LEI can be used to analyze groups' global expansion strategies especially the use of off-shore financial centres (OFCs). The Banque de France concludes that extending the obligation to have an LEI would thus help to make global financial transactions more transparent.
With specific to the Proposal for a Directive, GLEIF would like to suggest the Commission to include the LEI under the proposed “Article 8ad Scope and conditions of mandatory automatic exchange of information on undertakings required to report on indicators of minimum substance”. The current version of Article 8ad includes TIN and VAT number of the undertaking for information exchange. Adding the LEI would ensure that a global, open approach is taken for entity identification. This is especially important when dealing with entities that operate cross-border. Additionally, it enables more effective analysis and data sharing. Further supervisory authorities would benefit from the corporate hierarchy information freely available in the Global LEI System. As noted by the European System Risk Board, Identifying such groups, as well as their legal entities and overall structure, is crucial to ensuring financial stability. The LEI creates the worldwide infrastructure for the digital age in the domain of legal entities, just as the telephone book did for the analogue age.
GLEIF suggests that the addition of the LEI in the proposed Directive will complement existing measures and is an important foundational element for effective monitoring of tax abuse and aggressive tax planning.
Please find GLEIF's full response attached.
Read full responseResponse to Strengthening the quality of corporate reporting and its enforcement
1 Feb 2022
The Global Legal Entity Identifier Foundation (GLEIF) is pleased to respond to the European Commission Legislative Initiative for Corporate reporting – improving its quality and enforcement. GLEIF will focus its comments on the use of the Legal Entity Identifier (LEI) in the consultation.
GLEIF agrees that high-quality and reliable corporate reporting by listed companies is crucial for the efficiency of EU financial markets. The unambiguous identification of these companies from the very start is of great importance to prevent fraudulent or incorrect corporate reporting and strengthen the three pillars, namely corporate governance, statutory audit and supervision of corporate reporting.
GLEIF suggests that although the EU has a very comprehensive business register system and took essential steps to make the company information available for listed companies via Business Registers Interconnection System (BRIS). Still small investors or data users will need to overcome certain barriers (e.g., language, cost) for being able to obtain information on companies, particularly for unlisted ones.
The Global LEI System provides a solution to these barriers. It endorses the International Open Data Charter, which means the LEI data is to be freely used, reused, and redistributed by anyone, anytime, anywhere. Besides, the LEI data provides entity reference data in the native local language of the entity and in the transliterated version (as applicable). This enables users to understand the language used to represent the entity and also have a roman character representation of the name. And the GLEIF API is a globally accepted protocol for accessing identity information for legal entities in a digital and machine-readable fashion. The use of the Global LEI System by everyone, including, smaller and retail investors, is free of charge and without any barriers. Therefore, broader use of the Global LEI System enables investors to make informed decisions in a least costly manner.
Please find attached GLEIF's full response.
Read full responseResponse to Revision of EU rules on Anti-Money Laundering (recast of a former instrument)
26 Nov 2021
The Global Legal Entity Identifier Foundation (GLEIF) is pleased to provide comments to the European Commission for the "Proposal for preventing money laundering and terrorist financing – traceability of crypto-asset transfers."
First, GLEIF applauds the Commission for creating a harmonized rule-setting across the internal market to prevent fragmentation in the AML/CFT regimes. It is essential to set granular and standardized requirements across the Union, as demonstrated by the Commission's proposal for customer due diligence in the new AML Regulation, to adequately protect the internal market and reduce additional costs and burdens for operators providing cross-border services.
GLEIF agrees that the transfer of virtual assets, which have remained outside of the scope of Union legislation on financial services until now, poses money laundering and financing of terrorism risks. The flows of illicit money can be done through transfers of crypto-assets; hence it could damage the integrity, stability, and reputation of the financial sector and threaten the internal market of the Union. Therefore, GLEIF welcomes the inclusion of crypto-assets and crypto-asset service providers under the proposed recast of Regulation (EU) 2015/847.
However, GLEIF suggests that the applicability of the LEI should be extended to the originator and beneficiary of the crypto-asset transfer when these parties are legal entities. Extending the LEI requirement to the originator and beneficiary in the crypto-asset transfer would enable traceability and transparency of the parties. The LEI, a global standard, could be leveraged by all regulators, as well as participants in a crypto-asset transaction, across jurisdictions for uniquely identifying entities involved in creation of crypto-assets. In particular, parties involved in crypto-asset transactions could easily exchange information in a protected and private manner; but leverage the LEI to access the publicly available LEI data pool in order to identify precisely who is involved in a particular transaction when a transacting party is a legal entity.
GLEIF welcomes the inclusion of the LEI for payer and payee under Article 4 "Information accompanying transfers of funds" where provided by the payer to the payer's payment service provider for transfers of funds or transfer of crypto-assets from the Union to outside the Union as part of the complete information on the payer and the payee. First, GLEIF suggests that Article 4 could also make reference to the originator and beneficiary in the case of transfer of crypto-assets. Second GLEIF suggests the Commission extend the LEI requirement to include transfers from third countries to the EU (two-way traffic). This will enhance EU authorities and EU based financial institutions ability to combat money laundering or terrorist financing sourcing from third countries by enabling precise identification of the legal entities involved in fund transfers into the EU. The consistent use of the LEI for the beneficiary and originator would better enable tracing of the source of funds.
Please see GLEIF's full response in the attachment.
Read full responseMeeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)
11 Oct 2021 · Legal entity identifyer
Response to Requirements for Artificial Intelligence
6 Aug 2021
The Global Legal Entity Identifier Foundation (GLEIF) is pleased to provide comments to the European Commission's Proposed EU Artificial Intelligence Regulation. GLEIF will focus its comments on how using the Legal Entity Identifier (LEI) in the AI framework can enhance traceability and transparency.
GLEIF agrees that the nature of AI often relies on large and varied datasets, which significantly impacts the quality and reliability of the AI systems. Algorithms rely on quality data, and most firms recognize the need for quality data inputs. In particular poor-quality identification data renders AI and machine learning approaches less reliable, and worse, may result in missing the signal in the data and or unexpected behavior of the algorithm. For example, in the financial industry, a GLEIF research demonstrates that financial firms use on average 4 identifiers for their legal entity clients which leads to low confidence in the reliability of the associated client reference data. Considering the interconnectedness of the financial sector and institutions, several institutions' use of low-quality data can negatively impact risk assessment and exposure analysis and create a challenge for financial stability. This is also applicable in the usage of AI for financial risk solutions. These new solutions use AI technology to aggregate and analyze client data across financial crime detection systems such as know your customer (KYC) and anti-money laundering (AML) to improve outcomes. The success of these solutions will be dependent on the data input that is leveraged. Given the Commission's proposal aims to strengthen the Union's role significantly to shape global norms and standards and promote trustworthy AI and provide the Union with a powerful basis to engage further with its external partners, an explicit reference to the global data standards, including the LEI for legal entity identification as part of the dataset, should be key in international fora on issues relating to the identification in AI.
GLEIF would like to highlight that each AI solution is a product of multiple components. Each algorithm develops its patterns based on the input and the parameter set. The lack of labeled data is one of the most often encountered challenges when it comes to application of AI approaches. With the LEI code and the accompanying publicly available reference data, GLEIF offers a high quality labeled data set, that could be used for (i) different learning problems, (ii) as a benchmark data, or (iii) to be mapped to additional internal data in order to enhance the internal data and provide the data label.
In the proposed Regulation, it is mentioned that for high-risk AI systems, the requirements of high quality data, documentation and traceability, transparency, accuracy and robustness, are strictly necessary to mitigate the risks to fundamental rights and safety posed by AI and that are not covered by other existing legal frameworks. Harmonized standards and supporting guidance and compliance tools will assist providers and users in complying with the requirements laid down by the proposal and minimize their costs. To satisfy these requirements, GLEIF would like to suggest that the Commission adds the LEI to the requirements under the "ANNEX VIII INFORMATION TO BE SUBMITTED UPON THE REGISTRATION OF HIGH RISK AI SYSTEMS IN ACCORDANCE WITH ARTICLE 51" and “ANNEX V EU DECLARATION OF CONFORMITY” to uniquely and unambiguously identify the AI system provider.
Please see GLEIF's full response attached.
Read full responseMeeting with Axel Voss (Member of the European Parliament)
23 Jun 2021 · Common global standards for AI
Response to Supervisory data strategy
14 Jun 2021
The Global Legal Entity Identifier Foundation (GLEIF) is pleased to comment on the European Commission's Consultation on Supervisory Data Strategy. GLEIF will focus its comments on the use of the Legal Entity Identifier (LEI) in the consultation.
First, GLEIF suggests that achieving data consistency and harmonization is vital to reduce the current pain points of supervisory reporting in the EU. As highlighted in the roadmap, reporting entities have to report the same data set in different formats to various authorities. This practice causes redundancy and inconsistency in the regulatory landscape. The LEI, ensuring precision about the reporting legal entity, can help supervisory authorities to reduce inefficiencies and map the entity data across borders within the EU. The alternative, relying on national and multiple identifiers, negatively impacts ensuring efficient and accurate data sharing across EU supervisory authorities.
Therefore, GLEIF suggests that the foundational step to tackle these inefficiencies and establish an efficient supervisory data collection and sharing mechanism starts would be to adopt a unique, global transparent, interoperable, and harmonized identification approach. The Global LEI System is the only supranational solution backed by the regulators.
Please see the attachment for GLEIF's full response.
Read full responseResponse to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services
30 Mar 2021
The Global Legal Entity Identifier Foundation (GLEIF) is pleased to provide comments to the European Commission’s Proposal for a Regulation of the European Parliament and of the Council on a Single Market for Digital Services (Digital Services Act) and amending Directive 2000/31/EC. GLEIF will focus its comments on how a clear LEI requirement in Article 22 of the Proposed Regulation can help to set a consistent and standardized legal entity identification of traders in digital platforms and ensure transparency and consumer protection accordingly.
The Commission Staff Working Document Impact Assessment highlights that a quarter of the online intermediaries responding to the open public consultation said they did not have policies or identification measures for their business users established outside of the Union. Such measures are considered best practices to dissuade illicit sellers and to enable the enforcement of sanctions against them. On-boarding processes for traders differ for each online marketplace: whereas some are asking for detailed information on the identity of the traders, others require a mere email address. Consumer protection authorities have also often reported their difficulties to enforce the law against rogue traders online due to the lack of information on the identity of such traders, especially when they are not established in the EU.
Therefore, GLEIF suggests that the Commission has a consistent requirement for identity in the
Article 22(a) and (e) as follows:
(a) the name, the Legal Entity Identifier (LEI – ISO 17742), telephone number, and electronic mail address of the trader;
(e) the Legal Entity Identifier (LEI- ISO 17742) of the trader.
Since the Legal Entity Identifier reference data contains the local business registry number, headquarter and legal addresses of an entity, as well as information on the entity parent structure, requesting the LEI would make many data fields unnecessary to collect. It would also ensure that a consistent identity standard is applied to all traders thereby making this information meaningful to users of platforms. The current approach will result in identification information in different languages, specific to local jurisdictional requirements, and result in increased due diligence costs for online marketplaces.
GLEIF suggests that the LEI, the golden standard for entity identification, should be the first foundational step in ensuring that the intermediary service providers perform their Know Your Business Customer (KYBC) requirements on a standardized and consistent manner. It would also ensure that traders can provide the same identity standard to all online platforms therefore making it easier to engage with EU marketplaces for both EU based traders as well as third country traders. The LEI has a global footprint, which is issued in 200+ jurisdictions. Therefore, all entities, regardless of where they are registered, are eligible to obtain the LEI.
Please see GLEIF's full response attached.
Read full responseMeeting with Lucrezia Busa (Cabinet of Commissioner Didier Reynders)
23 Mar 2021 · Sustainable Corporate Governance
Response to Europe’s digital decade: 2030 digital targets
9 Mar 2021
The Global Legal Entity Identifier Foundation (GLEIF) is pleased to provide comments to the European Commission for the Initiative Titled Communication on Europe’s digital decade: 2030 digital targets. GLEIF will focus its comments on how leveraging the Legal Entity Identifier (LEI), a machine-readable digital standard for entity identification, can help to address cross-border and transnational frictions in upgrading Europe’s digital infrastructure and capacity.
GLEIF thinks that fragmentation of data space and single market for data among the Member States is a major risk for creating an EU fit for digital age and digital transformation. This fragmentation affects the usability of data and the value generation through data.
The usability of data will depend on its interoperability and standardization. When it comes to these two fundamental principles, GLEIF suggests that a critical question for EU authorities will be how to securely standardize the identification of entities looking to access/share data from/with other entities. A role for public authorities in that standardization is needed. The report on shaping the digital transformation in Europe highlights a lack of common standards for data and interoperability contributes to a lag in next-generation digital infrastructure. Secondly, regulation pertaining to the digital sector is not fully harmonized across the Member States (especially for emerging, high-impact technologies), which risks hindering the Digital Single Market in the EU.
GLEIF would like to emphasize that the LEI can play a substantial role in creating an interoperable Digital Single Market within the EU. Whenever the question of identifying securely a third party arises, as is the case in data access or data sharing models, the LEI could play a useful role as EU authorities reflect on their future data strategy. The LEI, as a global standard for unique, unambiguous legal entity identification, makes it an attractive supra-sectoral solution. It also ensures interoperability across member states as well as firms participating in EU solutions from third countries.
What is the LEI ?
• The LEI is a 20-character, alpha-numeric code, based on the ISO 17442 standard, is used for uniquely and unambiguously identifying legal entities globally. Each LEI contains information about an entity's business card and corporate structure. Simply put, the publicly available LEI data pool can be regarded as a global directory, which greatly enhances transparency in the global marketplace.
• Following the financial crisis of 2008, financial supervisors were unable to reconcile positions and dependencies across financial marketplaces easily. Supervisory authorities can now identify parties to financial transactions across markets, products, and regions for regulatory reporting and supervision in a consistent and systematic way with the introduction of the LEI.
• The private sector, particularly financial institutions, use the LEI as part of their data-driven approaches to client management procedures. The LEI is used to identify their clients in a standardized way thereby connecting internal and external databases through the LEI; so as to speak the same language in entity identification and verification.
• The Global LEI System is overseen by over 71 public authorities (including DG FISMA representing the European Commission, the European Central Bank, the EU supervisory authorities, and 16 member state authorities), under the auspices of the Financial Stability Board.
• In the European Union, the LEI is already required in regulatory reporting for entities subject to EMIR, MIFID II, MAR, CRR, SFTR, Solvency II, AIFMD, CRAR, CSDR, Transparency Directive, Securitization Regulation, Prospectus Regulation and SFTR. At the global level, more than 100 rules are referring to the LEI in Financial Stability Board jurisdictions .
Please see the attachment for GLEIF's full response.
Read full responseMeeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)
25 Jan 2021 · legal identifiers
Response to EU single access point for financial and non-financial information publicly disclosed by companies
13 Jan 2021
The Global Legal Entity Identifier Foundation (GLEIF) is pleased to provide comments to the European Commission's Initiative titled Proposal for a Directive/Regulation of the European Parliament and of the Council for a European single access point for financial and non-financial information publicly disclosed by companies. GLEIF will focus its comments to show how a mandatory use of the Legal Entity Identifier (LEI) in ESAP can ensure that the entity information can be easily accessible, interlinked and cross-referenced by investors.
GLEIF agrees that today the collection and dissemination of data is fragmented within the European Union. The relevant EU legislations requiring data reporting rarely prescribe specific dissemination channels. Data regarding both listed and non-listed entities is mainly found on the entity’s own website or in national registers where the annual financial report of a listed entity is published. While scattered information is a challenge for many investors as they cannot find data in a single place, thereby hindering their comparison abilities, the format for the public disclosure of information is not always prescribed in EU legislations. Different formats of information and language barriers prevent interoperability and usability of data.
Therefore, GLEIF suggests that the design of the ESAP should address these challenges by making sure that the data is machine readable, easily accessible and open for all users. Currently, listed companies shall submit their Annual Reports in a machine-readable format according to European Single Electronic Format (ESEF) requirements in XBRL Taxonomy. For demonstrating the value of embedding an organization’s LEI within an ESEF financial report, ESMA has published the Global LEI Foundation’s 2019 annual report on its website to provide a best practice example of a report published in the ESEF format, which other preparers can reference. LEI reference data includes business card information on an entity, including name and registered address, together with relationship data which confirms if the entity owns, or is owned by, other entities. This increased transparency relative to an entity’s ownership structure means that relationship networks between LEIs can be quickly and automatically established, since the LEIs of the filing entity, its affiliates, subsidiaries and parent companies are all provided in the new machine-readable ESEF format. Usefully, because the reference data is reverified annually by GLEIF accredited LEI issuers, data users can see the last update date of data reverification. The net result is a substantially more useful document for end users, which is also verifiably trustworthy, authentic and integral. By simply leveraging the LEI, regulators, investors, traders and other financial stakeholders, can consolidate and verify information on the filing entity faster and more conveniently than ever before.
Please see the attachment for GLEIF's full response.
Read full responseResponse to Sustainable corporate governance
8 Oct 2020
GLEIF suggests that setting clear and harmonized rules for due diligence in supply chains at the EU level is necessary for creating a level playing field for all EU companies. Many EU companies, small or big, are sourcing supplies from entities based in countries with lesser social, human rights or environmental standards. In some countries the identification and mitigation of related risks and impacts is weak. Supplier due diligence is a first foundational step to ensuring a minimum is met for social, human rights, and environmental standards. GLEIF proposes that the LEI should be a mandatory data element for due diligence requirements in the supply chain so as to ensure maximum transparency and clear communication with investors and supervisory authorities.
By mandating the LEI as part of due diligence in supply chains, the EU Commission could have the opportunity to introduce a standardized, uniform approach for entity identification across supply chains. GLEIF thinks that this clear guideline would be appreciated by many companies as this uniform approach would ensure transparency and clarity on who the suppliers they are engaging with. Setting out minimum mandatory requirements for all would also help to save certain costs compared to what companies are facing now, trying to keep up with disparate recommendations and expectations or trying to establish their own due diligence protocol.
As stated in the EU Commission's Final Report on due diligence requirements through the supply chain, the Commission could consider recognizing that certain third-party verification schemes could be used as part of the risk assessment and risk mitigation process. The LEI can be used as part of these third-party verification mechanisms. The report provides an interesting example of how certain provisions of the EU Timber Regulation were interpreted and applied in the German Administrative Court in Cologne. The Court found against a German company that sourced timber from a supplier in Democratic Republic of Congo, based on the fact that the company should have recognized that the certificate produced by the supplier was fake. As the defendant company failed to recognize this, they were found not to have met the due diligence requirement, which the Court emphasized is "not merely a purely formal requirement". The Court also referred to the seriousness of these requirements in light of the role of illegal logging in climate change.
This example shows the importance of easy, fast, and transparent access to a central open data source about legal entities' identity. If the German company had requested the LEI of the timber supplier in Congo, it could have a higher assurance about the identity of this company and could verify the information on the certificate before engaging in a business relationship. The Global LEI System solves the problem of entity identification for all legal entities on a global scale and creates the first level of trust.
Please see GLEIF's full response attached.
Read full responseResponse to European Digital Identity (EUid)
1 Sept 2020
The Global Legal Entity Identifier Foundation (GLEIF) is pleased to provide comments to the Inception Impact Assessment – Revision of the eIDAS Regulation – European Digital Identity (EUid). GLEIF will focus its comments on the use of the LEI in eIDAS.
Please see the attachment for GLEIF's full response.
Read full responseResponse to Detailed rules on certain aspects of the use of digital tools and processes in company law
1 Sept 2020
The Global Legal Entity Identifier Foundation (GLEIF) is pleased to provide feedback to the European Commission's Consultation on the Implementation Regulation laying down rules for the application of Directive (EU) 2017/1132 of the European Parliament and of the Council as regards technical specifications and procedures for the system of interconnection of registers (and repealing Commission Implementing Regulation (EU) 2015/884). GLEIF will focus its comments on the use of the Legal Entity Identifier (LEI) in the consultation.
Please see the attachment for GLEIF's full response.
Read full responseResponse to Action Plan on the Capital Markets Union
3 Aug 2020
The Global Legal Entity Identifier Foundation (GLEIF) is pleased to provide comments to the European Commission's roadmap for its Capital Markets Union Action Plan. GLEIF will focus its comments on the use of the Legal Entity Identifier (LEI) in the consultation. GLEIF will make comments for recommendations presented in clusters A, B, C and D in the Final Report.
Please see the attachment for GLEIF's full response.
Read full responseMeeting with Lucrezia Busa (Cabinet of Commissioner Didier Reynders)
7 Jul 2020 · Role of the Legal Identity Identifier (LEI) in improving supply chain transparency
Response to Climate change mitigation and adaptation taxonomy
16 Apr 2020
The Global Legal Entity Identifier Foundation (GLEIF) is pleased to provide comments to the European Commission Inception Impact Assessment titled Commission Delegated Regulation on a Climate Change Mitigation and Adaptation Taxonomy. GLEIF will focus its comments on the use of the Legal Entity Identifier (LEI) in the Impact Assessment.
Similar to the use of a standard for industry classification in the Taxonomy, GLEIF suggests the Technical Expert Group adopt an international standard, the Legal Entity Identifier (LEI), for clear and consistent identification of entities that are required to provide company level disclosures under Taxonomy Regulation. As stated in the Final Report of the Technical Expert Group, the International Platform on Sustainable Finance aims to encourage dialogue and where appropriate coordination on development of new taxonomies. Therefore, use of international standards, such as the ISO 17742 LEI standard, would help harmonization efforts of international taxonomies and creating the common vocabulary and understanding for investors and policy makers.
The starting point for assessing a company’s taxonomy alignment in the EU taxonomy is to break down of entity’s economic activities. Therefore, it is crucial to demonstrate that, for example, activity A, activity B, activity C are performed by the Company A but not Company A’s Branch B or Company A’s Parent Z. Therefore, GLEIF suggests the Commission require the Legal Entity Identifier of the company as the first building block for assessing a company’s taxonomy alignment. Making the LEI mandatory as part of the company disclosure and creating a common language for all entity actors would help data comparability and consistency not only for regulators but also for investors across borders. Given the EU Commission aims to harmonize reporting frameworks and standards in the EU, reduce administrative burden of reporting institutions and facilitate stakeholders’ access to sustainability information, leveraging the LEI as a common standard identifier for the reporting entities would be logical and beneficial for all reporting institutions and investors.
Please see the attachment for GLEIF's full response.
Submitted by: Stephan Wolf, CEO GLEIF
Stephan.Wolf@gleif.org
Read full responseResponse to Action Plan on anti-money laundering
10 Mar 2020
The Global Legal Entity Identifier Foundation (GLEIF) is pleased to provide comments to the European Commission on its Roadmap titled Towards a New Comprehensive Approach to Preventing and Combating Money Laundering and Terrorism Financing. GLEIF will focus its comments on the use of the Legal Entity Identifier (LEI) in the Roadmap.
The LEI initiative is driven by the Financial Stability Board (FSB) on behalf of the finance ministers and governors of central banks represented in the Group of Twenty (G20). The LEI is a 20-character, alphanumeric code based on the ISO 17442 standard developed by the International Organization for Standardization (ISO). The LEI connects to key reference information that enables clear and unique identification of legal entities participating in financial transactions. Each LEI contains information about an entity’s ownership structure, answering the questions of ‘who is who’ and ‘who owns whom’. It provides a universally recognized identifier paired with essential entity data, rigorous verification processes and high data quality.
The ability of the world’s financial ecosystem to curb fraud, terrorist financing and other illicit financial activity, is hindered by its reliance on outdated processes for identity verification. Financial institutions face the following fundamental challenge in identity management: low quality, non-uniform data sources are not easy to implement, prevent interoperability and promote inefficiency, which limits the capacity to put in place effective surveillance processes.
It is stated in the July 2019 Report from the Commission to the European Parliament and the Council on the assessment of recent alleged money laundering cases involving EU credit institutions that in some instances, it appears that the parent company had difficulties in forming an accurate and complete overview of the existing risks in the group. Some of the cases involved banking activities undertaken in different parts of a group, through branches established in different Member States or third countries, or through subsidiaries located in Member States other than where the headquarters are established. The Report confirms that supervision of such entities is also rather fragmented and inefficient. Information sharing within the EU and with third countries are uneven and often established on an ad hoc basis without a consistent and standardized approach.
GLEIF therefore argues that mandating the use of the LEI under the EU’s AML framework could prove beneficial to protect the EU internal market from criminals attempting to launder money and finance terrorism for the following reasons:
(1) Strengthen entity identification and verification processes in the EU financial ecosystem – Where the LEI can provide the necessary strong identification required to help diminish the risks related to language ambiguity, estimation and human intervention;
(2) Futureproof AML/CFT efforts vis-à-vis the digital revolution – As the LEI is highly interoperable, it can easily be used in both centralized and decentralized identity management systems, as well as with eIDAS-compliant digital certificates;
(3) Enable faster, better and more cost-effective compliance – Today, banks spend around EUR 35 billion on client onboarding annually, presenting a clear opportunity for increasing efficiency and reducing costs. By widely adopting the LEI, banks could unlock an estimated EUR 1.75-3.5 billion per annum by improving full time employee (FTE) productivity in client onboarding alone to focus on the fight against financial crime.
Please see the attachment for GLEIF’s full response.
Submitted by:
Stephan Wolf, CEO GLEIF
Read full responseResponse to Revision of Non-Financial Reporting Directive
26 Feb 2020
The Global Legal Entity Identifier Foundation (GLEIF) is pleased to provide comments to the European Commission on the Revision of the Non-Financial Reporting Directive Roadmap. GLEIF will focus its comments on the use of the Legal Entity Identifier (LEI) in the consultation. Please kindly see the attachment for GLEIF's response.
Submitted by:
Stephan Wolf, CEO GLEIF
Stephan.Wolf@gleif.org
Read full responseResponse to Report on the Application of the eIDAS Regulation
23 Oct 2019
Please find the file attached for the Global Legal Entity Identifier Foundation (GLEIF) response to the European Commission on the Report on the Application of the eIDAS Regulation Evaluation Roadmap.
Karla McKenna
Head of Standards
GLEIF
on behalf of Stephan Wolf
CEO GLEIF
Read full responseResponse to European Partnership for innovative small and medium-sized enterprises
22 Aug 2019
Please find the feedback of the Global Legal Entity Identifier Foundation (GLEIF), submitted by Stephan Wolf, CEO GLEIF, in the attached file.
Read full responseResponse to Evaluation of Regulation 515/97
22 Aug 2019
Please find the feedback of the Global Legal Entity Identifier Foundation (GLEIF) submitted by Stephan Wolf, CEO GLEIF, in the attached file.
Read full response9 Jul 2018
Response submitted on behalf of Stephan Wolf, CEO GLEIF
Read full response