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LEI Requirements for US Companies: A Complete Guide for 2026

Picture of Steve Waite
Steve Waite
CMO, Ubisecure RapidLEI
LEI Requirements for US Companies: A Complete Guide for 2026

Table of Contents

By RapidLEI | Last updated: May 2026

If your organization trades derivatives, files with the SEC, sends cross-border payments, or manages private funds, you need a Legal Entity Identifier (LEI) to meet US regulatory requirements. This guide covers every US regulation that mandates an LEI, who is affected, key compliance deadlines, and how to register.

What is an LEI?

A Legal Entity Identifier (LEI) is a unique 20-character alphanumeric code, standardized under ISO 17442, that identifies any legal entity involved in financial transactions worldwide. Each LEI Number links to verified reference data including the entity’s legal name, registered address, and ownership structure, published in the open-access Global LEI Index maintained by the Global Legal Entity Identifier Foundation (GLEIF).

The LEI system was established after the 2008 financial crisis when the G20 and Financial Stability Board recognized that regulators had no reliable, machine-readable way to identify counterparties across global markets. As of 2026, more than 3.2 million LEI Numbers have been issued globally, and over 300 regulations across jurisdictions mandate or encourage their use (source: GLEIF).

Which US Regulations require an LEI Number?

The following table summarizes the major US regulations and global standards that require US organizations to hold an active LEI Number.

RegulationRegulatorWho It AffectsLEI Requirement
17 CFR Part 45 (Swap Data Reporting)CFTCSwap dealers, major swap participants, counterparties, DCMs, SEFs, DCOs, SDRsMandatory for all recordkeeping and swap data reporting
Regulation S-K / EDGAR FilingsSECPublic companies and registrants filing with EDGARRequired in applicable SEC filings
Form PF (amended Feb 2024)SEC / CFTCSEC-registered investment advisers to private funds with $150M+ AUMRequired; amended form compliance deadline October 1, 2026
FATF Recommendation 16 (Travel Rule)FATF (implemented via national law)Banks, PSPs, VASPs involved in cross-border transfersLEI required as identifier for legal entity originators/beneficiaries; compliance by 2030
QFC RecordkeepingFDICInsured depository institutions in troubled conditionLEI required to identify counterparties in QFC records
Financial Data Transparency Act CongressAll entities reporting to federal financial regulatorsEstablishes LEI as a common data standard across agencies

Do I need an LEI for CFTC Swap Reporting?

Yes. Under 17 CFR Part 45, Section 45.6, every swap counterparty that is eligible to receive an LEI must obtain one, maintain it, and use it in all recordkeeping and swap data reporting submitted to swap data repositories.

This applies to swap dealers, major swap participants, swap execution facilities (SEFs), designated contract markets (DCMs), derivatives clearing organizations (DCOs), swap data repositories (SDRs), and end-user counterparties to swaps. The LEI must conform to ISO Standard 17442 and be issued by a GLEIF-accredited LEI Issuer.

A critical compliance detail: under Section 45.6(a)(3), if a financial entity reporting counterparty executes a swap with a counterparty that is eligible for an LEI but does not yet have one, the reporting counterparty must use best efforts to get an LEI assigned to that counterparty before reporting the swap creation data. Failure to do so requires reporting the non-LEI counterparty’s identity directly to the CFTC.

A lapsed LEI does not satisfy the requirement. If your LEI status is anything other than “Active” in the Global LEI Index, your swap reporting is non-compliant.

Learn more about LEI for CFTC compliance →

Do Asset Managers and Private Fund Advisers need an LEI Number?

Yes. SEC-registered investment advisers who manage private funds with at least $150 million in assets under management are required to file Form PF, which uses LEI Numbers to identify both the adviser and the funds they manage.

Form PF applies to hedge fund advisers, private equity fund managers, and advisers also registered with the CFTC as commodity pool operators (CPOs) or commodity trading advisers (CTAs). The SEC and CFTC adopted significant amendments to Form PF in February 2024, expanding reporting requirements around hedge fund events, private equity disclosures, and fund-level data.

Key deadline: The compliance date for the amended Form PF has been extended to October 1, 2026. Large hedge fund advisers will begin filing on the amended form for the quarter ending September 30, 2026. Annual filers will use the new form for filings due by April 30, 2027.

Private fund advisers should ensure that the LEI Numbers for their firm and every fund entity they advise are active and current well before October 2026. A lapsed LEI on a fund can delay filings and create compliance risk during the transition to the amended form.

See LEI Solutions for Asset Managers →

Do US Banks need an LEI?

Yes, and the requirements are expanding. US banks need LEI Numbers for multiple overlapping reasons: CFTC swap reporting obligations, FDIC QFC recordkeeping, SEC filing requirements, and the growing role of LEI Numbers in cross-border payment messaging.

The most significant near-term development is the revised FATF Recommendation 16 (the “Travel Rule”), adopted in June 2025. The updated rule requires that cross-border payment messages carry verified originator and beneficiary information. For legal entities, the rule now explicitly requires one of three identifiers: a connected Business Identifier Code (BIC), a Legal Entity Identifier (LEI), or another unique official identifier.

This is new. The revised Recommendation 16 differentiates between natural persons and legal persons for the first time, and the LEI is positioned by both FATF and GLEIF as the primary identifier for organizations in qualifying transactions. FATF members representing over 200 jurisdictions must implement these requirements through national legislation by 2030.

In the US, the Bank Secrecy Act (BSA) Travel Rule already imposes originator information requirements on wire transfers. The revised FATF standard will drive further alignment. US banks processing international wire transfers should begin embedding LEI Numbers in ISO 20022 payment messages now rather than waiting for a hard domestic compliance deadline.

For banks managing LEI Numbers at scale across a corporate group or client portfolio, RapidLEI’s EnterpriseLEI platform provides bulk management, volume discounts, and API integration.

See LEI Solutions for Banks →

Learn more about FATF 16 & 24 and the LEI →

What happens if your LEI lapses?

A lapsed LEI can cause immediate, tangible problems for US organizations:

ConsequenceWhy It Happens
Swap transactions rejectedCFTC requires an active LEI for all swap data reporting under 17 CFR Part 45
SEC filings incomplete or delayedMissing or lapsed LEI data in EDGAR submissions triggers compliance flags
Cross-border payments held or rejectedIntermediary banks screening against FATF R16 requirements may flag lapsed LEI Numbers
Counterparty onboarding blockedBanks and trading partners performing KYB checks rely on active LEI status
Regulatory penaltiesNon-compliance with CFTC, SEC, or FDIC recordkeeping rules can result in enforcement action

LEI Numbers are valid for one year. If not renewed, the status changes from “Active” to “Lapsed” in the Global LEI Index. The fix is straightforward: choose a multi-year plan (available in 1, 3, or 5-year terms) that auto-renews, so your LEI never falls out of compliance.

How Much Does an LEI Cost in the US?

RapidLEI offers three pricing tiers for US organizations:

PlanAnnual CostTotal CostSavings
1 year$70/year$70
3 years$67/year$2005%
5 years$63/year$31510%

Multi-year plans auto-renew to prevent lapses. All plans include same-day issuance and publication to the Global LEI Index.

For organizations managing multiple LEI Numbers, EnterpriseLEI offers bulk registration, dedicated account management, and API integration.

How to Register an LEI for a US Company

Registering an LEI with RapidLEI takes approximately five minutes and follows three steps:

  1. Select your validity period. Choose a 1-year, 3-year, or 5-year plan. Multi-year plans auto-renew to prevent lapses and include volume discounts.
  2. Confirm your organization details. RapidLEI automatically retrieves verified company data from US business registries. You review and confirm rather than filling forms from scratch.
  3. LEI is issued and published. Most LEI registrations are fully automated and completed in minutes. Once issued, your LEI is published directly to the Global LEI Index.


Register Your US LEI Now →

Frequently Asked Questions

What is the difference between an LEI and an EIN?

An EIN (Employer Identification Number) is a US-specific tax identification number issued by the IRS. An LEI is a global identifier standardized under ISO 17442 that is recognized across 300+ regulations in jurisdictions worldwide. The EIN identifies your entity to the IRS for tax purposes; the LEI identifies your entity to regulators, counterparties, and financial systems globally. They serve different purposes and most US organizations involved in regulated financial activity need both.

Can I use the same LEI across SEC, CFTC, and FATF requirements?

Yes. Each legal entity is assigned a single LEI that is used across all regulatory reporting, filings, and payment messaging. This is by design: the purpose of the Global LEI System is to provide one unique, universal identifier per entity.

How long does it take to get an LEI?

With RapidLEI, most LEI Numbers are issued on the same day as application, often within minutes. The automated platform retrieves company data from official US business registries, minimizing manual input and verification delays.

Do I need a separate LEI for each fund I manage?

Yes. Each legal entity, including individual funds, trusts, and SPVs, requires its own LEI. Asset managers who advise multiple funds should ensure every entity in their portfolio has an active LEI, particularly ahead of the October 2026 Form PF compliance deadline.

What if my LEI was issued by another provider?

You can transfer your LEI to RapidLEI using a streamlined transfer process that operates within GLEIF’s transfer rules. The transfer consolidates your LEI management into one account for easier renewal and administration. Start a transfer →

Is RapidLEI accredited by the GLEIF?

Yes. RapidLEI has been accredited by the Global Legal Entity Identifier Foundation (GLEIF) since June 2018. RapidLEI is the largest LEI Issuer globally, alongside organizations like Bloomberg, London Stock Exchange Group, and Euronext.

Key takeaways

US regulatory requirements for the LEI are expanding. Between the CFTC’s swap reporting rules, the SEC’s filing and Form PF requirements (amended form deadline: October 1, 2026), FATF Recommendation 16’s travel rule for cross-border payments, and the trajectory of the Financial Transparency Act, no segment of the US financial services industry can afford to treat entity identification as an afterthought.

The organizations that register and maintain their LEI Numbers proactively avoid rejected transactions, delayed filings, and unnecessary compliance risk.

Get started with RapidLEI

RapidLEI is a GLEIF-accredited LEI Issuer, operating since 2018. We issue, renew, and manage Legal Entity Identifiers for organizations, funds, and trusts in over 150 jurisdictions worldwide.

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