SEBI has issued a new circular on “Introduction of Legal Entity Identifier (LEI) for issuers who have listed and/ or propose to list non-convertible securities, securitised debt instruments and security receipts” vide circular no. SEBI/HO/DDHS/DDHS_Div1/P/CIR/2023/64 dated May 03, 2023.
Few points worth noting are mentioned below. Request you to ensure compliance with the same on priority basis within the Regulatory timeline.
Salient features of the Circular:
1. LEI is designed to create a global reference data system that uniquely identifies every legal entity, in any jurisdiction, that is party to a financial transaction.
2. Presently, RBI directions, inter alia, mandate non-individual borrowers having aggregate exposure of above Rs. 25 crores, to obtain LEI code.
3. Pursuant to SEBI Circular dated May 03, 2023, issuers having outstanding listed non-convertible securities as on August 31, 2023, shall report/ obtain and report the LEI code in the Centralized Database of corporate bonds, on or before September 1, 2023.
4. Further, issuers proposing to issue and list non-convertible securities, on or after September 01, 2023, shall report their LEI code in the Centralized Database of corporate bonds at the time of allotment of the ISIN.
| Category of security | Relevant Regulation | Applicability | Timeline |
| Non-convertible Securities | SEBI (Issue and listing of Non-convertible Securities) Regulations, 2021 | Issuer proposing to issue and list non-convertible security | On or after September 1, 2023 |
| Issuer having outstanding listed non-convertible security as on August 31, 2023 | On or before September 1, 2023 | ||
How to Obtain LEI Code?
1. Entities can obtain the LEI code from any of the Local Operating Units (LOUs) accredited by the Global Legal Entity Identifier Foundation (GLEIF).
2. In India, the LEI code may be obtained from Legal Entity Identifier India Ltd (LEIIL), a subsidiary of the Clearing Corporation of India Limited (CCIL), which has been recognised by the Reserve Bank of India as issuer of LEI under the Payment and Settlement Systems Act, 2007 and is accredited by the GLEIF as the LOU in India for issuance and management of LEI codes. https://www.ccilindia-lei.co.in/Default.aspx
1) Amount for one year
– 5,015/- (4250/- plus GST @ 18%) for New Applications
– 3,540/- (3000/- plus GST @ 18%) for Renewal Applications
2) Fee structure including 1st year issuance
| Multi-Year Contract Option | SEZ | Non SEZ ( inclusive of 18% GST) | |
|---|---|---|---|
| Fees + 18% GST | Total fees | ||
| 2 years – New application & Renewal for next 1 year | 7,100 | 7100+ 1,278 | 8378/- |
| 3 years – New application & Renewal for next 2 years | 9,750 | 9,750+ 1,755 | 11,505/- |
| 4 years – New application & Renewal for next 3 years | 12,350 | 12,350+ 2,223 | 14,573/- |
| 5 years – New application & Renewal for 4 years | 14,750 | 14,750+ 2,655 | 17,405/- |
3) Fee structure for renewals only
| Multi-Year Contract Option | SEZ | Non SEZ ( inclusive of 18% GST) | |
|---|---|---|---|
| Fees + 18% GST | Total fees | ||
| Renewal application for 2 years | 5,850 | 5850+ 1,053 | 6,903/- |
| Renewal application for 3 years | 8,500 | 8,500+ 1,530 | 10,030/- |
| Renewal application for 4 years | 11,100 | 11,100+ 1998 | 13,098/- |
| Renewal application for 5 years | 13,500 | 13,500+ 2,430 | 15,930/- |
LEI Number is valid for one year. LEIL shall send reminder email well in advance in case of single year payment or multi-year payment to submit required documents before the due date
In the multi year option, if the validity of LEI extends beyond the end -date of contract for which term the multi- year fee payment is made due to non
submission of required documents for renewal in time, an additional fee of Rs 250/- per month will be levied for the period for which it extends the end date.
Entities are, therefore, requested to submit the required documents timely.
Role of Depository:
The Depositories shall:
1. Map the LEI code to existing ISINs by September 30, 2023; and
2. for future issuances, map the LEI code provided by the issuers with the ISIN at the time of activation of the ISIN.
CS Avik Gupta
