Why are some companies only registered with an LEI and not in a commercial register?

What is an LEI?

A Legal Entity Identifier (LEI) is a globally standardized 20-character code used to uniquely identify legally distinct entities that participate in financial transactions. It is issued under the supervision of the Global Legal Entity Identifier Foundation (GLEIF).

The LEI system was introduced to improve transparency in financial markets by making it possible to clearly identify counterparties worldwide.

Does an LEI replace a commercial register, and why can the data differ?

No. An LEI does not replace a commercial register.

A commercial register (such as the Handelsregister in Germany or Companies House in the UK) records the legal existence and legal status of a company under national law.
An LEI, in contrast, is a global identifier used in financial markets and does not constitute a legal registration.

Because these systems serve different purposes and are maintained independently, their data may differ:

• A company may be registered in a commercial register without having an LEI
• A company may have both a commercial register entry and an LEI
• Some entities may appear only in the LEI system

Differences can also arise because:

• LEI data depends on active maintenance by the entity or its representative
• Register data follows formal legal filing and publication processes

In practice, LEI data may sometimes appear more current (if actively maintained), or less complete (if not regularly updated).

Why do some entities only appear in LEI data?

Some entities exist in the LEI system but are not found in a traditional commercial register because of differences in scope.

The LEI system covers a broad range of legally recognized entities, including those that are not always required to register as companies.

Examples include:

• investment funds
• special purpose vehicles (SPVs)
• public sector entities
• international or supranational organizations

In addition, many entities are required to obtain an LEI because they participate in financial markets. Regulatory frameworks (such as MiFID II or EMIR in the EU) require an LEI for certain financial transactions.

This means:
An entity with an LEI is not necessarily a traditional company, but it is still a recognized legal entity within financial systems.

How does LEI registration work?

LEIs are not issued by government registers but by accredited issuing organizations, known as Local Operating Units (LOUs).

The registration process typically includes:

1. Application through an LEI issuer
2. Submission of entity reference data (e.g. name, address, legal form)
3. Validation against authoritative or official sources
4. Assignment of the LEI
5. Publication in the global LEI database maintained by GLEIF

This creates a standardized global dataset of legal entities participating in financial markets.

How are updates handled (e.g. address changes)?

LEI data must be actively maintained and regularly renewed, typically on an annual basis.

If an entity wants to update its information (for example, an address change):

1. The update is submitted to the LEI issuing organization
2. The issuer verifies the updated information
3. The updated data is published in the LEI system

Important:

• LEI data is not automatically synchronized with commercial registers
• The responsibility for keeping the data up to date lies with the entity itself or its representative

Key takeaway

• The LEI is a global identification system for financial transparency, not a legal registration system
• It complements, but does not replace, commercial registers
• Some entities appear only in the LEI system due to differences in legal and regulatory scope
• LEI data must be actively maintained, which can lead to differences compared to register data