Cyprus: Legal Entity Identifiers: The Cyprus Perspective

With the implementation from 3 January 2018 of EU Directive 2014/65/EU on markets in financial instruments (MiFID II) and accompanying Regulation (EU) No 600/2014 (MiFIR), additional requirements have been introduced on certain entities regulated under MiFID II/MiFIR to collect and report LEIs of their clients in certain circumstances.

What is a LEI?

A Legal Entity Identifier (LEI) is a 20-digit, alphanumeric code that allows for the clear and unique identification of legal entities participating in financial transactions. LEIs are used widely within the global and the European regulatory regimes for financial services, as they provide for an effective and reliable database for identifying parties to financial transactions.

What (or who) is a 'legal entity' for LEI purposes?

The European Securities and Markets Authority (ESMA) in a briefing on LEIs issued on 9 October 2017 (ESMA Briefing Note) clarifies that for the purposes of obtaining a LEI, the term 'legal entity' includes but is not limited to "unique parties that are legally or financially responsible for the performance of financial transactions, or have the legal right in their jurisdiction to enter independently into legal contracts, regardless of whether they are incorporated or constituted in some other way e.g. trust, partnership, contractual. It excludes natural persons, but includes individuals acting in a business capacity. It also includes governmental organisations and supranationals."

Why obtain a LEI?

LEIs are typically collected by regulated persons for the purposes of complying with their regulatory reporting requirements within the financial services regime. The most recent and significant expansion to the requirement on entities, including Cypriot entities, to obtain LEIs has resulted from the application of MiFID II and MiFIR.

As noted in the ESMA Briefing Note, the common framework enabled by the use of LEIs is "crucial to identifying clearly each exposure for risk management of financial transactions, to create transparency, and conduct market surveillance".1

Beyond MiFID/MiFIR, the LEI is an important characteristic in key European financial services regimes as implemented in Cyprus and across the EU, such as:

  • Alternative Investment Fund Managers Directive (AIFMD): funds and fund managers Solvency II: pension funds and insurance companies
  • Transparency Directive: issuers of financial instruments listed on Regulated Markets
  • European Markets Infrastructure Regulation (EMIR): counterparties to derivatives contracts as well as beneficiaries, brokers, CCPs and clearing members
  • Market Abuse Regulation (MAR): issuers of financial instruments; entities involved or reporting in suspicious transactions
  • Capital Requirements Regulation (CRR): credit and financial institutions
  • Credit Rating Agencies Regulation (CRAR): credit rating agencies and rated entities
  • Central Securities Depositories Regulation (CSDR): CSDs, CSDs' participants
  • Securities Financing Transactions Regulation (SFTR): parties involved in securities financing transactions and the beneficiaries of the rights and obligations arising from these
  • Prospectus Regulation – issuers of securities offered to the public or admitted to trading on a regulated market situated or operating within an EU member state.

What is the relevance of LEIs in Cyprus?

Cyprus has given full effect to MiFID II through the enactment of the Investment Services and Investment Activities and Regulated Markets Law 2017 (the IS Law), which came into force on 3 January 2018. The new local legislation repeals and recasts the vast majority of rules contained in the Investment Services and Investment Activities and Regulated Markets Law 2007 which implemented Directive 2004/39/EC on markets in financial instruments (MiFID).

The IS Law together with MiFIR constitute the core of the new regime. MiFIR, as a European regulation, is directly applicable in Cyprus from the same date as MiFID II and is not further implemented under the new IS Law. For an overview of the MiFID II regime as implemented in Cyprus, please refer to our article here.

In particular, MiFIR introduces the following requirements for entities to be identifiable by a LEI:

  • Investment firms that execute transactions in financial instruments
  • The clients (buyer, seller) on whose behalf the investment firm executes transactions, when the client is a legal entity
  • The client of the investment firm on whose behalf the trading venue is reporting under Article 26(5) of MiFIR, when the client is a legal entity
  • The person who makes the decision to acquire the financial instrument, when this person is a legal entity (for example, this includes investment managers acting under a discretionary mandate on behalf of its underlying clients)
  • The investment firm transmitting the order
  • The entity submitting a transaction report (ie trading venue, approved reporting mechanism (ARM), investment firm)
  • The issuer of any financial instrument listed and/or traded on a trading venue

Accordingly, in the ESMA Briefing Note, ESMA emphasises that investment firms reporting under Article 26 of MiFIR should have appropriate arrangements in place in order to collect and verify the LEI of their clients before the transaction takes place. In turn, operators of trading venues reporting under Article 27 must have appropriate arrangements in place in order to collect and verify the LEI of the issuer of the financial instrument admitted to trading or traded on its venue.

Both investment firms and operators of trading venues must ensure that the length and construct of the code are compliant with the ISO 17442 standard, that the code is included in the Global LEI database and that it pertains to the client concerned.

Further considerations for Cypriot issuers

On 20 September 2017 the Cyprus Securities and Exchange Commission (CySEC), which is the competent authority in Cyprus regarding the implementation of MiFID II and MiFIR, released Circular C2372 (Circular) on the acquisition of a LEI. The Circular is addressed to Cypriot issuers, these being issuers of financial instruments traded on a trading venue (ie a regulated market, a multilateral trading facility, or an organised trading facility). The Circular also discusses the circumstances under which systematic internalisers are required to obtain the LEI of issuers of financial instruments traded on their platform, in particular in relation to:

  • Financial instruments where the underlying is financial instrument traded on a trading venue.
  • Financial instruments where the underlying is an index or a basket composed of financial instruments traded on a trading venue.

The Circular also provides details on the procedure for obtaining a LEI through the Cyprus Stock Exchange, and further informs trading venues and systematic internalisers of the LEI 'Registration Agent' tool introduced by the GLEIF, which can be used by the regulated entities to guide issuers through the procedure to obtain a LEI.

Obtaining a LEI: The Harneys solution

Given the increasing importance of the LEI for our clients, Harneys have put together a team ready to meet your LEI requirements. From LEI initial registration, amendments and annual renewals, our LEI team is available to guide you through the process. 


The LEI is becoming a key characteristic of the financial services regime in Cyprus, and it can be expected that its use will only increase. With respect to the new requirements introduced under MiFIR, Cypriot issuers should ensure that they obtain a LEI where needed in a timely manner, in order to avoid any disruptions in trading. In turn, Cypriot entities regulated under MiFID II should ensure that they have in place the necessary systems to be able to collect and report the LEI of the relevant entities as necessary. 




The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on

Click to Login as an existing user or Register so you can print this article.

Some comments from our readers…
“The articles are extremely timely and highly applicable”
“I often find critical information not available elsewhere”
“As in-house counsel, Mondaq’s service is of great value”

Related Topics
Related Articles
Up-coming Events Search
Font Size:
Mondaq on Twitter
Mondaq Free Registration
Gain access to Mondaq global archive of over 375,000 articles covering 200 countries with a personalised News Alert and automatic login on this device.
Mondaq News Alert (some suggested topics and region)
Select Topics
Registration (please scroll down to set your data preferences)

Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice):

  • To allow you to personalize the Mondaq websites you are visiting to show content ("Content") relevant to your interests.
  • To enable features such as password reminder, news alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our content providers ("Contributors") who contribute Content for free for your use.

Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below.

Mondaq has a "free to view" business model. Our services are paid for by Contributors in exchange for Mondaq providing them with access to information about who accesses their content. Once personal data is transferred to our Contributors they become a data controller of this personal data. They use it to measure the response that their articles are receiving, as a form of market research. They may also use it to provide Mondaq users with information about their products and services.

Details of each Contributor to which your personal data will be transferred is clearly stated within the Content that you access. For full details of how this Contributor will use your personal data, you should review the Contributor’s own Privacy Notice.

Please indicate your preference below:

Yes, I am happy to support Mondaq in maintaining its free to view business model by agreeing to allow Mondaq to share my personal data with Contributors whose Content I access
No, I do not want Mondaq to share my personal data with Contributors

Also please let us know whether you are happy to receive communications promoting products and services offered by Mondaq:

Yes, I am happy to received promotional communications from Mondaq
No, please do not send me promotional communications from Mondaq
Terms & Conditions (the Website) is owned and managed by Mondaq Ltd (Mondaq). Mondaq grants you a non-exclusive, revocable licence to access the Website and associated services, such as the Mondaq News Alerts (Services), subject to and in consideration of your compliance with the following terms and conditions of use (Terms). Your use of the Website and/or Services constitutes your agreement to the Terms. Mondaq may terminate your use of the Website and Services if you are in breach of these Terms or if Mondaq decides to terminate the licence granted hereunder for any reason whatsoever.

Use of

To Use you must be: eighteen (18) years old or over; legally capable of entering into binding contracts; and not in any way prohibited by the applicable law to enter into these Terms in the jurisdiction which you are currently located.

You may use the Website as an unregistered user, however, you are required to register as a user if you wish to read the full text of the Content or to receive the Services.

You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these Terms or with the prior written consent of Mondaq. You may not use electronic or other means to extract details or information from the Content. Nor shall you extract information about users or Contributors in order to offer them any services or products.

In your use of the Website and/or Services you shall: comply with all applicable laws, regulations, directives and legislations which apply to your Use of the Website and/or Services in whatever country you are physically located including without limitation any and all consumer law, export control laws and regulations; provide to us true, correct and accurate information and promptly inform us in the event that any information that you have provided to us changes or becomes inaccurate; notify Mondaq immediately of any circumstances where you have reason to believe that any Intellectual Property Rights or any other rights of any third party may have been infringed; co-operate with reasonable security or other checks or requests for information made by Mondaq from time to time; and at all times be fully liable for the breach of any of these Terms by a third party using your login details to access the Website and/or Services

however, you shall not: do anything likely to impair, interfere with or damage or cause harm or distress to any persons, or the network; do anything that will infringe any Intellectual Property Rights or other rights of Mondaq or any third party; or use the Website, Services and/or Content otherwise than in accordance with these Terms; use any trade marks or service marks of Mondaq or the Contributors, or do anything which may be seen to take unfair advantage of the reputation and goodwill of Mondaq or the Contributors, or the Website, Services and/or Content.

Mondaq reserves the right, in its sole discretion, to take any action that it deems necessary and appropriate in the event it considers that there is a breach or threatened breach of the Terms.

Mondaq’s Rights and Obligations

Unless otherwise expressly set out to the contrary, nothing in these Terms shall serve to transfer from Mondaq to you, any Intellectual Property Rights owned by and/or licensed to Mondaq and all rights, title and interest in and to such Intellectual Property Rights will remain exclusively with Mondaq and/or its licensors.

Mondaq shall use its reasonable endeavours to make the Website and Services available to you at all times, but we cannot guarantee an uninterrupted and fault free service.

Mondaq reserves the right to make changes to the services and/or the Website or part thereof, from time to time, and we may add, remove, modify and/or vary any elements of features and functionalities of the Website or the services.

Mondaq also reserves the right from time to time to monitor your Use of the Website and/or services.


The Content is general information only. It is not intended to constitute legal advice or seek to be the complete and comprehensive statement of the law, nor is it intended to address your specific requirements or provide advice on which reliance should be placed. Mondaq and/or its Contributors and other suppliers make no representations about the suitability of the information contained in the Content for any purpose. All Content provided "as is" without warranty of any kind. Mondaq and/or its Contributors and other suppliers hereby exclude and disclaim all representations, warranties or guarantees with regard to the Content, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. To the maximum extent permitted by law, Mondaq expressly excludes all representations, warranties, obligations, and liabilities arising out of or in connection with all Content. In no event shall Mondaq and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use of the Content or performance of Mondaq’s Services.


Mondaq may alter or amend these Terms by amending them on the Website. By continuing to Use the Services and/or the Website after such amendment, you will be deemed to have accepted any amendment to these Terms.

These Terms shall be governed by and construed in accordance with the laws of England and Wales and you irrevocably submit to the exclusive jurisdiction of the courts of England and Wales to settle any dispute which may arise out of or in connection with these Terms. If you live outside the United Kingdom, English law shall apply only to the extent that English law shall not deprive you of any legal protection accorded in accordance with the law of the place where you are habitually resident ("Local Law"). In the event English law deprives you of any legal protection which is accorded to you under Local Law, then these terms shall be governed by Local Law and any dispute or claim arising out of or in connection with these Terms shall be subject to the non-exclusive jurisdiction of the courts where you are habitually resident.

You may print and keep a copy of these Terms, which form the entire agreement between you and Mondaq and supersede any other communications or advertising in respect of the Service and/or the Website.

No delay in exercising or non-exercise by you and/or Mondaq of any of its rights under or in connection with these Terms shall operate as a waiver or release of each of your or Mondaq’s right. Rather, any such waiver or release must be specifically granted in writing signed by the party granting it.

If any part of these Terms is held unenforceable, that part shall be enforced to the maximum extent permissible so as to give effect to the intent of the parties, and the Terms shall continue in full force and effect.

Mondaq shall not incur any liability to you on account of any loss or damage resulting from any delay or failure to perform all or any part of these Terms if such delay or failure is caused, in whole or in part, by events, occurrences, or causes beyond the control of Mondaq. Such events, occurrences or causes will include, without limitation, acts of God, strikes, lockouts, server and network failure, riots, acts of war, earthquakes, fire and explosions.

By clicking Register you state you have read and agree to our Terms and Conditions