RBI regulations for mandating Legal Entity Identifier in India (2019 extensions update)
RBI (Reserve Bank of India) has mandated the use of LEI for large corporate borrowers and use of LEI in non-derivative markets. RBI hopes to achieve better quality and accuracy for monitoring the health of the financial system. It also hopes to achieve better managed risk in the markets. Therefore the RBI has mandated the use of LEI for the following markets and entities.
LEI for large corporate borrowers
Banks are required to ask for an LEI from all large corporate borrowers. RBI has implemented a schedule to enforce the regulation in a phased manner. If the large corporate borrowers fail to provide an LEI it’s credit facilities shall not be renewed or new credit will not be offered.
RBI also encourages to require an LEI from the parent entities, partner entities and subsidiaries of the large corporate borrowers.
The schedule for implementing LEI regulations to borrowers:
| Total Exposure to SCBs | To be completed by |
| ₹ 1000 crore and above | Mar 31, 2018 |
| Between ₹ 500 crore and ₹ 1000 crore | Jun 30, 2018 |
| Between ₹ 100 crore and ₹ 500 crore | Mar 31, 2019 |
| Between ₹ 50 crore and ₹ 100 crore | Dec 31, 2019 |
LEI in non-derivative markets
RBI has mandated the use of LEI in the markets regulated by RBI. All participants, other than private individuals, transacting in the markets regulated by RBI shall obtain the LEI in the given schedule below:
- Government securities market
- Money market -markets for any instrument with a maturity of one year or less)
- Non derivative forex markets (settlement of instruments before the spot date)
If the entity fails to receive an LEI before the due date, they can not transact in these financial markets. Neither has an issuer, investor or seller or buyer.
Schedule for implementation (2019 update – RBI has updated and extended the deadline as following):
| Phase | Net Worth of Entities | Current Deadline | Extended Deadline |
| Phase I | above Rs.10000 million | April 30, 2019 | December 31, 2019 |
| Phase II | between Rs.2000 million and Rs 10000 million | August 31, 2019 | December 31, 2019 |
| Phase III | up to Rs.2000 million | March 31, 2020 | March 31, 2020 |
All inter-bank non-derivative forex transactions are subjected for an LEI. Non-derivative forex transactions with clients shall be under the LEI requirement if the amount of the transaction is equal or exceeds 1 Million USD or it’s equivalent.
More about the RBI regulation can be found from their statement.