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While underlining the importance of the LEI requirements, to support the smooth introduction of the MiFID II rules, the ESMA statement of 20th December 20171 provided for trading venues to report their own LEI codes instead of LEI codes of non-EU issuers that do not have their own LEI codes. In addition, the statement envisaged a possibility for investment firms to provide a service triggering the obligation to submit a transaction report to the client, from which it did not previously obtain an LEI code, under the condition that before providing such service the investment firm obtains the necessary documentation from this client to apply for an LEI code on his behalf. This also required National Competent Authorities (NCAs) to temporarily amend a validation rule in their transaction reporting systems to allow for the acceptance of transaction reports where the LEI issuance date is after the transaction execution date.
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