Small Self-Administered Schemes (SSASs) trading or wishing to trade in equities and bonds, ETFs, derivatives and certain debt related instruments (reportable financial instruments) will now have to obtain a Legal Entity Identifier (LEI) before trades can take place. This has been introduced under the Markets in Financial Instruments Directive (MiFID ii) with the intention of reducing abuse and preventing fraud. 

The new LEI regulations will create a global data system to strengthen investor protection and increase international financial market transparency. An LEI is a 20-character identification reference number given to every legal entity that carries out financial transactions on a regulated stock exchange. 

The changes in legislation take effect from 3 January 2018 and will apply to all HMRC registered occupational pension schemes, including SSASs, that hold existing, or create new, accounts after this date and those schemes will need to obtain an LEI before trades (including sales) can take place. The changes do not apply to Self Invested Personal Pensions (SIPPs).

The London Stock Exchange (LSE) is the only authorised LEI issuing organisation in the UK.  Once a LEI has been obtained, it must be renewed annually if the SSAS is to continue to trade.

The fee to the LSE for initial individual registration is £115 plus VAT.  The current LSE annual renewal fee is £70 plus VAT.

Some investment houses are already registering and applying for LEIs for new and existing clients and these fees can be expected to be deducted from scheme funds. However, for those firms that do not, Dentons will arrange for the application of the LEI on behalf of the scheme and manage the scheme annual renewals at the discounted price. 

Dentons' Service

Further, where firms are making bulk registrations, a discount to the LSE fee can be obtained. We are pleased to confirm that Dentons has obtained discounts and will be passing these on to their clients: 

The discounted rates are:
  • Initial registration £70 plus VAT including administration
  • Annual renewal £60 plus VAT including administration
If you have any doubts about whether your clients’ schemes require an LEI please contact your usual Dentons' Consultant.