ISO 17442 LEI - GLEIF implementation of ROC Policies

ISO 17442 LEI - GLEIF implementation of ROC Policies

By TC 68 Communications


The Global Legal Entity Identifier (LEI) Foundation has begun operationalizing the collection of important additional data required by three Regulatory Oversight Committee (ROC) Policies/Guidance into the Global LEI System - listed below. 


Guidance for General Government Entities

ROC Policy -Legal Entity Events (2018)

LEI ROC Policy on Fund relationships


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The current implementation timeline is:

  • All LEIs issued or renewed after March 31, 2022 must provide the new relevant data. 
  • The GLEIF will have test files for the new file formats available by May 31, 2021. These will be available publicly on when ready.

More on the policies:


Government Entities

In December 2020, ROC published its. ROC clarified that a better identification of government entities with the LEI could enhance accountability for tracking government spending and enhance transparency by collecting government financial data.  A government entity is eligible for a LEI as long as it can acquire legal rights and obligations under the national law to which it is subject. The ROC based its guidance off of the government section of the System of National Accounts (SNA 2008) document by UN, EC, OECD, IMF, World Bank.


Legal Entity Events:

Also known as Corporate Actions. The final policy was issued October 30, 2018 and sets forth the ROC’s policy for incorporating legal entity events and data history in the Global LEI System (GLEIS). 


Fund Relationships

The policy introduces 3 distinct relationship types which will be collected for Funds: Fund Management Entity, Umbrella Structure, Master Feeder.  Definitions for each are contained in the ROC Policy.  As part of the GLEIF’s implementation of the ROC policy, GLEIF will be adjusting its accreditation and data quality guidelines to associate fund types defined in national or regional law to the 3 relationship types.