Rule · MAJOR

COMMON.LEI_CONSISTENCY

Legal Entity Identifiers agree across the party sections and the rest of the draft

How the status is set

• Missing: no section issuer, offeror or trading_platform_operator has text other than a placeholder.
• Review: a party section has text but no party section carries an LEI with valid check digits, since point 5 allows another identifier required pursuant to applicable national law in place of the LEI; a valid LEI in another section appears in no party section; or the issuer section names more than one valid LEI. An LEI that the draft gives for a person other than the parties counts for neither: the crypto-asset service provider in charge of the placing (field E.31 of Table 2, C.22 of Table 3), a custodian of the reserve assets (G.8 of Table 3), or a person other than the issuer who offers the token, seeks its admission to trading or draws up the white paper (AA.1 and AA.3 of Table 3, A.27 of Table 4). The field label, or the sentence that holds the code, names that role before it.
• Pass: none of the above. Codes with invalid check digits are reported by COMMON.LEI_CHECK_DIGITS, not here.

Legal basis

Annex I, Part A, point 5, Part B, point 5, Part C, point 5, Annex II, Part A, point 5, Annex III, Part A, point 5 MiCAR

• https://eur-lex.europa.eu/eli/reg/2023/1114/oj/eng

Checked on 2026-10-27 against the Official Journal text in English and German: point 5 of Annex I Parts A, B and C and of Annex II and III Part A names the legal entity identifier or another identifier required pursuant to applicable national law, and Art. 2(1)(b) and (c) of Implementing Regulation (EU) 2024/2984 ask for the LEI where available.

Synthetic examples

Each example is linted when this page is generated. The build fails if a result differs.

{
  "title": "Synthetic rule example",
  "type": "other",
  "sections": {
    "summary": "LEI 9999SYNTH0000ZZQ0166."
  }
}

{
  "title": "Synthetic rule example",
  "type": "other",
  "sections": {
    "issuer": "Synthetic Issuer AG.",
    "summary": "LEI 9999SYNTH0000ZZQ0166."
  }
}

{
  "title": "Synthetic rule example",
  "type": "other",
  "sections": {
    "issuer": "Synthetic Issuer AG, a fictional company. LEI: 9999SYNTH0000ZZQ0166.",
    "summary": "The issuer's LEI is 9999SYNTH0000ZZQ0263."
  }
}

{
  "title": "Synthetic rule example",
  "type": "other",
  "sections": {
    "issuer": "Synthetic Issuer AG, a fictional company. LEI: 9999SYNTH0000ZZQ0166.",
    "summary": "The issuer's LEI is 9999SYNTH0000ZZQ0166."
  }
}

{
  "title": "Synthetic rule example",
  "type": "other",
  "sections": {
    "issuer": "Synthetic Issuer AG, a fictional company. LEI: 9999SYNTH0000ZZQ0166.",
    "offer_or_admission": "CASP identifier: 9999SYNTH0000ZZQ0263"
  }
}

Limitations

• Reads every section of the draft; findings are anchored to the issuer section.
• Works offline on the characters of each code. It does not confirm that an LEI is registered, current or held by the entity the draft names.
• Status and severity are fixed by the rule. A draft cannot waive or downgrade them.
• Does not recognise the other identifiers that point 5 allows in place of the LEI, so a draft whose party sections carry no valid LEI goes to review. Once one party section carries a valid LEI, another party section without an LEI does not change the result.
• Knows a person other than the parties only from the words before the code in its sentence or field label (CASP, crypto-asset service provider, custodian, other than the issuer, other persons drawing up, and the German Kryptowerte-Dienstleistungen, Verwahrer, nicht mit dem Emittenten identisch). A role named in an earlier sentence does not carry over: in "The custodian is Example Bank AG. Its LEI is ..." the code is still compared with the party sections.

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