Unless your company is subject to the reporting requirements for derivative transactions under the European Market Infrastructure Regulation (EMIR), it is likely that the first time you come across a form requiring the insertion of a “Legal Entity Identifier code” is the PDMR notification form that the FCA require to be completed and filed electronically in respect of transaction by persons discharging managerial role responsibilities and persons closely associated with them.
With effect from 1 January 2017, the European Electronic Access Point Delegated Regulation (EU)2016/1437, which supplements the Transparency Directive, will require the FCA to use LEIs for all issuers that have securities admitted to trading on a regulated market for which the FCA is the competent national authority. We understand that the FCA will be publishing information about this requirement towards the end of the year.
Whilst it does not appear that there will be a sanction if a company has securities admitted to trading on a regulated market without having obtained an LEI by 1 January 2017, this may change in the future. It is thought that there may be high demand for an LEI and so it may be sensible to apply for an LEI sooner rather than later. LEIs are obtained on application to the London Stock Exchange Group (http://www.lseg.com/LEI). The website states that the initial allocation cost will be £115 plus VAT with annual maintenance costs of £70 plus VAT per LEI.