LEI Registration in IndiaThe Legal Entity Identifier your bank asks for, and the three RBI thresholds behind it

What an LEI is, and who issues it in India

An LEI is a 20-character code that identifies a legal entity taking part in financial transactions, with a public record of who that entity is.

In India it is issued by Legal Entity Identifier India Limited, which operates at ccilindia-lei.co.in. RBI's own FAQs state that LEIL is recognised as an issuer of LEI by the Reserve Bank of India, and that it functions as a Local Operating Unit accredited by the Global Legal Entity Identifier Foundation.

Two things follow. The LEI is not an MCA registration, so it has nothing to do with your CIN, and no government fee applies to it: the issuer charges its own fee. And because it is a global identifier, the same code follows your entity into every transaction a bank reports, which is exactly why the bank will not proceed without it.

We are not an LEI issuer. We prepare the application, get the documents in the form LEIL expects, deal with the queries and hand you the code, and you pay LEIL's fee at actuals.

The three RBI requirements

Three separate directions, three thresholds, three different populations. Most entities that need an LEI need it for the first reason.

RBI has separately required LEI for participation in the over-the-counter derivatives and non-derivative markets, so a treasury or a market participant should have the position checked against the direction that applies to it rather than against this table.

Borrowers: aggregate exposure of ₹5 crore and above

This is the one that reaches ordinary companies. RBI's circular RBI/2022-23/34 dated 21 April 2022 requires non-individual borrowers enjoying aggregate exposure of ₹5 crore and above from banks and financial institutions to obtain an LEI.

The deadlines were phased by exposure band, and all three have passed:

So a borrower in this bracket without an LEI today is not approaching a deadline. It has passed one, and the consequence sits in the next section.

The lenders covered are broad: scheduled commercial banks, all-India financial institutions, small finance banks, local area banks, primary urban cooperative banks and NBFCs.

Large-value payments: ₹50 crore and above on RTGS and NEFT

For payment transactions of ₹50 crore and above in the RBI's centralised payment systems, RTGS and NEFT, a non-individual entity needs an LEI. RBI's FAQs on the requirement are explicit that an LEI is not required for customer transactions where both the remitter and the beneficiary are individuals.

If your business moves single payments at that size, whether for property, equipment, a group transfer or a settlement, the LEI has to exist before the payment, not after it is returned.

Cross-border transactions: ₹50 crore and above

For cross-border transactions of ₹50 crore and more, undertaken on or after 1 October 2022, the AD bank records a valid LEI. The requirement was introduced by A.P. (DIR Series) Circular No. 20 dated 10 December 2021.

One detail worth knowing before your bank explains it less kindly: once an entity has an LEI, the bank reports it for all that entity's cross-border transactions, irrespective of the value. The threshold decides when you must obtain one. It does not limit where the code is used afterwards.

Cross-border remittances bring their own certification work: see Form 15CA and 15CB, and, where the money is coming in as investment, FDI reporting and FC-GPR filing.

Related: IEC registration for exporters and importers, Indian subsidiary for foreign-owned entities, and the FLA return for entities with foreign investment.

Who is outside these requirements

• Individuals, for the payment requirement: RBI's FAQs say an LEI is not required for customer transactions where both remitter and beneficiary are individuals.
• Non-individual borrowers below ₹5 crore of aggregate exposure, for the borrower requirement, though a bank may still ask as a matter of its own policy.
• Entities whose payments and remittances sit below ₹50 crore, for the other two requirements.

Where you borrow in your own name as a proprietor, the classification of the borrower is the bank's, and it is worth asking the branch rather than assuming. We check the position with the sanction letter in front of us.

How aggregate exposure is computed

The circular is specific, and this is where clients get the answer wrong in their own favour. The aggregate sanctioned limit or the outstanding balance, whichever is higher, is reckoned, and both fund-based and non-fund-based exposures count.

Three consequences:

• An unused limit still counts. A ₹6 crore sanctioned cash credit drawn to ₹2 crore is a ₹6 crore exposure for this purpose.
• Non-fund-based facilities count. Bank guarantees and letters of credit are in, which catches contractors and importers who think of themselves as small borrowers.
• Exposure is aggregated across lenders. Two banks at ₹3 crore each put you inside the requirement.

What happens if a borrower has no LEI

The circular states the consequence directly: borrowers who fail to obtain LEI codes shall not be sanctioned any new exposure, nor shall they be granted renewal or enhancement of any existing exposure.

That is not a penalty in rupees. It is worse in practice: the working capital renewal stops, the enhancement you were counting on stops, and the new term loan does not get sanctioned. It usually surfaces at the worst possible moment, three weeks before a limit expires, which is why an LEI belongs on the checklist with the audited accounts and the CMA data rather than in the panic that follows.

Documents and information for the application

LEIL confirms its current list at the time of application, and it varies by entity type, so we check it before we ask you for anything. In practice, be ready with:

• Constitution documents: certificate of incorporation and the memorandum and articles for a company, the LLP agreement and incorporation certificate for an LLP, the partnership deed for a firm, or the trust deed or registration certificate for a trust or society
• PAN of the entity
• Latest audited financial statements. See our accounting service
• Proof of the registered address
• A board resolution or authorisation in favour of the person signing the application
• KYC of the authorised signatory
• Details of the entity's parent or holding company, where there is one, because the LEI record captures the ownership structure
• The entity's legal name exactly as it appears in its constitution documents

The last point is the one that causes re-work. The LEI record is a public identity record, so the name, the address and the ownership have to match the documents, not the way the business is commonly written.

Renewal: an LEI is not a one-time registration

LEIs are renewed annually. The issuer supplies the renewal service, and the record's data is confirmed as part of it.

A bank looks for a valid LEI, not merely an allotted one, so a lapsed code has the same practical effect as no code at all when a facility comes up for renewal. Two habits prevent the problem:

• Diarise the renewal date from the LEI record itself, and treat it like a statutory due date on your compliance calendar rather than a subscription.
• Tell us when the entity's name, registered address or ownership changes, because the record has to be updated, not just renewed.

Fees for an LEI

No government fee. The LEI issuer sets its own fee schedule on cost recovery principles, as GLEIF's own documentation describes, and that fee is paid to LEIL at actuals.

We do not publish the issuer's amounts here because they are LEIL's to set and change. We confirm the current figure with you in writing before the application goes in.

Our fee for LEI registration and renewal

Fee on quote after a free review. The review establishes which RBI requirement applies to you, which decides whether this is urgent or not.

How we do it

1. Applicability. We work out which of the three requirements reaches you, adding up sanctioned limits and outstanding balances across lenders, fund-based and non-fund-based.
2. Name and identity check. We fix the entity's legal name, address and ownership as they will appear in the LEI record, against the constitution documents.
3. Document pack. We confirm LEIL's current list, collect what is needed and get the authorisation signed.
4. Apply. We submit the application to LEIL, pay the issuer's fee from your funds and respond to its queries.
5. Hand over. You get the LEI, the record as published, and the renewal date in writing.
6. Renewal. We diarise the annual renewal and update the record when the entity's details change.

Five mistakes we see

1. Counting only what is drawn. Exposure is the sanctioned limit or the outstanding balance, whichever is higher.
2. Forgetting bank guarantees and letters of credit. Non-fund-based exposure counts towards the ₹5 crore.
3. Adding up one bank at a time. The test is aggregate exposure across banks and financial institutions.
4. Treating the LEI as permanent. LEIs are renewed annually, and a bank wants a valid one.
5. Waiting for the renewal season. Without an LEI a borrower in the bracket gets no new exposure and no renewal or enhancement of an existing one.