# LEI Registration in India for Cross Border Payments and Loans (2026)

> Source: https://krystal7.com/insights/lei-code-registration-india-cross-border-transactions
> Publisher: Krystal7 Consultants (Krystal7 Innovations Private Limited), Gurugram, India
> Author: CA Nandini
> Published: 13 Jan 2026; updated 24 Oct 2026
> Summary: An Indian company needs an LEI for any FEMA transaction of INR 50 crore or more, a rule in force since 1 Oct 2022 under RBI Circular No. 20 of 2021.

*Written by CA Nandini Hasija, Krystal7 Consultants. Last updated 23 October 2026.*

## AI Overview Summary

- Since 1 Oct 2022, an Indian company must give its bank a valid LEI for any FEMA transaction of INR 50 crore or more, under A.P. (DIR Series) Circular No. 20 of 2021.
- Once a company holds an LEI, its bank must report it on every cross border transaction, whatever the value. The INR 50 crore test applies to each transaction, not to a yearly total.
- Under RBI's 21 Apr 2022 circular, a non individual borrower with aggregate exposure of INR 5 crore or more from banks or NBFCs needs an LEI, or the lender cannot sanction, renew or enhance credit.
- A client forex deal of USD 1 million or more settling on or before the spot date needs an LEI under RBI's 29 Nov 2018 directions, and RBI treats a lapsed LEI as invalid.
- Get the LEI from Legal Entity Identifier India Limited (LEIL) or any other GLEIF accredited issuer, and renew it every year so it does not lapse.

**An Indian company needs a Legal Entity Identifier (LEI) before its bank will process a FEMA transaction of INR 50 crore or more. The rule comes from RBI A.P. (DIR Series) Circular No. 20 of 10 Dec 2021 and has applied since 1 Oct 2022. Other RBI rules require an LEI for borrowers with INR 5 crore of credit and for OTC derivatives. Client forex deals of USD 1 million or more and RTGS or NEFT payments of INR 50 crore or more need one too.**

This page sets out each RBI rule that makes an LEI mandatory and how to get one from LEIL or another issuer. It then covers cost, renewal and where the code appears in remittance paperwork. It is written for the Indian subsidiary of a foreign parent and the finance team abroad that funds it.

## When does an Indian company need an LEI for cross border payments?

An Indian company needs an LEI when a single capital or current account transaction under FEMA is INR 50 crore or more. RBI A.P. (DIR Series) Circular No. 20 of 10 Dec 2021 has required this since 1 Oct 2022. The test applies to each transaction. After the company gets an LEI, the bank reports it on every transaction.

The circular sets these duties for AD Category I banks:

- From 1 Oct 2022, the bank must get an LEI from a resident non individual for each FEMA transaction of INR 50 crore and above.
- The rule covers both directions. A dividend paid out and a share subscription received both count.
- The bank may still process a transaction where the non resident counterparty has no LEI. RBI allowed this so that payments are not disrupted.
- Once an entity has an LEI, the bank must report it for all the entity's transactions, irrespective of size.
- The bank must capture LEI information in its systems and validate each LEI against the GLEIF database.
- The bank should tell its customers about the rule and advise entities with large transactions to obtain an LEI in time.

RBI issued the [circular](https://rbi.org.in/scripts/BS_CircularIndexDisplay.aspx?Id=12206) under sections 10(4) and 11(1) of the Foreign Exchange Management Act, 1999 (FEMA). Its reference is RBI/2021-22/137. It does not replace any other approval a transaction needs.

"Capital or current account" covers almost every cross border flow a subsidiary has. A share subscription from the parent, an ECB drawdown, a dividend, a royalty, an import payment and an export receipt are all inside it. The circular has no list of exempt purposes.

The rule applies only to resident entities that are not individuals. A company, LLP, partnership firm, trust or society is inside it. A resident individual paying for a child's tuition abroad is outside it, whatever the amount.

## What is a Legal Entity Identifier and who issues it in India?

A Legal Entity Identifier is a 20 character alphanumeric code under the ISO 17442 standard. It identifies one legal entity in financial transactions anywhere in the world. Each LEI can represent only one entity, as the Global Legal Entity Identifier Foundation (GLEIF) states on its [introductory page](https://www.gleif.org/en/about-lei/introducing-the-legal-entity-identifier-lei).

The code links to a public record of reference data. GLEIF describes two levels:

- Level 1 answers "who is who": verified reference data about the entity itself, such as its legal name and registered address.
- Level 2 answers "who owns whom": the entity's [direct and ultimate accounting consolidating parent](https://www.gleif.org/en/lei-data/access-and-use-lei-data/level-2-data-who-owns-whom).

GLEIF does not issue LEIs itself. It accredits LEI issuers, which older RBI circulars call Local Operating Units (LOUs). An entity "can use the registration services of any issuer that is accredited for its authorized jurisdiction(s)", in GLEIF's words on its [issuer page](https://www.gleif.org/en/about-lei/get-an-lei-find-lei-issuing-organizations).

In India, RBI's circulars of 29 Nov 2018, 5 Jan 2021 and 10 Dec 2021 name Legal Entity Identifier India Limited (LEIL) as the Indian source of LEIs. The last two add that RBI recognises LEIL as an issuer under the Payment and Settlement Systems Act, 2007. All three let an entity use any other LOU accredited by GLEIF.

RBI introduced the LEI in phases after the global financial crisis of 2008. Its stated aim was better financial data and risk management. The table below shows how the requirement spread.

## Which RBI rules make an LEI mandatory?

Five RBI instruments make an LEI mandatory for an Indian entity. They cover FEMA transactions, borrowers, OTC derivatives, the money and forex markets, and large RTGS or NEFT payments. Each rule has its own threshold. A company can fall under several at once.

| RBI instrument and date | Who must hold an LEI | Threshold | Consequence without LEI |
|---|---|---|---|
| FMRD.FMID No. 14/11.01.007/2016-17, 1 Jun 2017 | Non individual participants in OTC rupee interest rate, foreign currency and credit derivatives | No value threshold | Phased in from 2017; see the derivatives section |
| DBR.No.BP.BC.92/21.04.048/2017-18, 2 Nov 2017, extended by DOR.CRE.REC.28/21.04.048/2022-23, 21 Apr 2022 | Non individual borrowers of banks, financial institutions, urban cooperative banks and NBFCs | Aggregate exposure of INR 5 crore and above | No new exposure, renewal or enhancement |
| FMRD.FMID.No.10/11.01.007/2018-19, 29 Nov 2018 | Non individual participants in government securities, money and non derivative forex markets | All interbank forex deals; client forex deals of USD 1 million and above | Cannot transact in these markets |
| DPSS.CO.OD No.901/06.24.001/2020-21, 5 Jan 2021 | Non individual remitters and beneficiaries in RTGS and NEFT | INR 50 crore and above per payment, from 1 Apr 2021 | Bank must advise the entity to obtain an LEI and include it in the message |
| A.P. (DIR Series) Circular No. 20, 10 Dec 2021 | Resident non individuals in FEMA capital or current account transactions | INR 50 crore and above per transaction, from 1 Oct 2022 | Bank must obtain the LEI before it processes the transaction |

For a foreign owned subsidiary, two rows matter most. The FEMA row decides large remittances. The borrower row catches almost any subsidiary with a working capital line of INR 5 crore or more.

## How does the INR 50 crore cross border rule work in practice?

The INR 50 crore rule applies to one transaction at a time, in either direction, on capital or current account. The bank must hold a valid LEI before it processes that transaction. RBI's FAQ of 7 Feb 2023 adds that the LEI then goes on all later transactions, and covers non resident accounts, merchanting trade and guarantees.

RBI published seven [FAQs on the circular](https://rbi.org.in/SCRIPTs/FAQView.aspx?Id=154) on 7 Feb 2023. They settle most of the questions banks raise with us:

| Situation | RBI position (FAQ of 7 Feb 2023) | What it means for a subsidiary |
|---|---|---|
| Transaction below INR 50 crore | LEI must be reported for all transactions once the entity has one | Quote the LEI on every remittance after you obtain it |
| Non resident counterparty without LEI | FAQ refers banks to paragraph 2 of the circular, which lets them proceed | Your parent does not need an LEI for your remittance to go through |
| Debit or credit to a non resident account in India | Covered by FEMA, so the circular applies | A payment from a resident to an NRO or NRE account counts |
| SWIFT message format | The circular prescribes no SWIFT field | Your bank decides where the LEI goes in its own forms |
| Three party transaction, such as merchanting trade | Each remittance leg has two parties; obtain the LEI for each leg | Each leg is tested separately |
| Non fund facilities, such as letters of credit and guarantees | Banks ensure LEI compliance at the issue stage | The bank checks the LEI when it issues the LC or guarantee |

The per transaction test means splitting a payment avoids the circular on paper. We advise against it. A split remittance looks like structuring, and the 2018 forex rule below often catches the smaller pieces anyway.

The INR 50 crore figure is a rupee value. For a foreign currency remittance, the bank applies its own conversion rate on the day. A payment near the line can cross it because the rupee moved, so get the LEI before you plan a large payment.

## Does a company with bank loans need an LEI?

Yes, if the company is a non individual borrower with aggregate exposure of INR 5 crore or more. RBI's circular of 21 Apr 2022 extended the 2 Nov 2017 bank rule to urban cooperative banks and NBFCs. A borrower without an LEI cannot get new exposure, renewal or enhancement from the lender.

The 21 Apr 2022 [circular on LEI for borrowers](https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=12301) (RBI/2022-23/34) sets these rules:

- Exposure includes all fund based and non fund based exposure, both credit and investment.
- The lender takes the higher of the aggregate sanctioned limit and the outstanding balance.
- Lenders may work out exposure from their own records, the CRILC database or a declaration by the borrower.
- Departments and agencies of the Central and State Governments are exempt. Public sector companies and statutory corporations are not.

The circular phased in the deadlines by exposure band:

| Total exposure from banks and financial institutions (INR) | LEI deadline |
|---|---|
| Above 25 crore | 30 Apr 2023 |
| Above 10 crore, up to 25 crore | 30 Apr 2024 |
| 5 crore and above, up to 10 crore | 30 Apr 2025 |

All three deadlines have passed. Any company with credit exposure of INR 5 crore or more should already hold an LEI. Non fund limits count. So a subsidiary with a guarantee line and a working capital limit often crosses INR 5 crore without noticing.

RBI consolidated many of its banking circulars into entity wise directions in 2025. Its [draft Credit Risk Management Directions for commercial banks](https://rbi.org.in/scripts/BS_ViewREwiseDraftDirections.aspx?id=12) carried the LEI for borrowers rule in Chapter VII, paragraphs 61 to 66. The threshold was the same INR 5 crore. RBI's final [Commercial Banks Credit Risk Management Directions, 2025](https://www.rbi.org.in/scripts/BS_ViewMasDirections.aspx?id=13153) are on its site, updated as on 1 Oct 2026. We could not open the final text, so we do not state its paragraph numbers or what it repeals.

The thresholds above come from the 21 Apr 2022 circular. The RBI site shows no withdrawal note on it on 23 Oct 2026. Ask your lender which direction it applies and get the LEI requirement in writing.

## Do OTC derivatives and forex deals need an LEI?

Yes. Non individual participants in OTC rupee interest rate, foreign currency and credit derivatives have needed an LEI since RBI's circular of 1 Jun 2017. RBI's 29 Nov 2018 directions extended the rule to government securities, money markets and non derivative forex markets. Client forex deals of USD 1 million or more need an LEI.

A forward contract to hedge a parent's invoice is an OTC foreign currency derivative. So is a currency swap on an ECB. The 1 Jun 2017 circular (FMRD.FMID No. 14/11.01.007/2016-17) phased the LEI in for these markets. RBI records this in the opening section of its [29 Nov 2018 directions](https://rbi.org.in/Scripts/NotificationUser.aspx?ID=11424).

The 29 Nov 2018 directions (RBI/2018-19/83) set these rules for non derivative markets:

| Market | Who needs an LEI | Threshold |
|---|---|---|
| Government securities | Non individual participants | No value threshold |
| Money market (instruments of up to one year) | Non individual participants | No value threshold |
| Forex, interbank, settling on or before the spot date | All participants | All transactions |
| Forex, client deals, settling on or before the spot date | Non individual clients | USD 1 million and above, or the equivalent |

Three further points in those directions matter to a foreign group:

- Non resident entities in these markets also need an LEI. A fund that is not a legal entity at home may use the LEI of its parent or management company.
- Transactions on recognised stock exchanges are outside the directions.
- "Lapsed LEI codes shall be deemed invalid" for transactions in RBI regulated markets.

The forex row is the one finance teams miss. When your bank sells you USD 2 million for an import payment, that is a client forex deal settling on or before spot. On our reading, the 2018 directions require an LEI for it, even though the payment is far below INR 50 crore. Ask your bank how it applies the USD 1 million line to remittance conversions.

## Do RTGS and NEFT payments need an LEI?

Yes, for payments of INR 50 crore or more by non individual entities. RBI's DPSS circular of 5 Jan 2021 has required this since 1 Apr 2021. Member banks must include both the remitter's and the beneficiary's LEI in RTGS and NEFT messages for these payments.

RBI issued the [RTGS and NEFT circular](https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=12010) (RBI/2020-21/82) under the Payment and Settlement Systems Act, 2007. It relies on section 10(2) read with section 18. Its annex names the message fields:

- RTGS customer payments carry the LEI in the "Remittance information" field.
- NEFT outward debit messages carry it in the "Sender to Receiver Information" field.

Banks must also keep records of all RTGS and NEFT transactions of INR 50 crore or more. This rule matters for a subsidiary when it moves large sums within India. Examples are a payment for a land or plant purchase, or a transfer between its own accounts at two banks.

## How do you get an LEI from LEIL or another issuer?

Apply online to LEIL or any LEI issuer accredited by GLEIF for India. The company submits its legal details, proof of registration, an authorisation for the applicant and its parent information. The issuer validates the data, then publishes the LEI in the GLEIF database. The code is then visible to every bank.

The process at most issuers follows the same steps:

1. Search the [GLEIF database](https://www.gleif.org/en/about-lei/get-an-lei-find-lei-issuing-organizations) first. Check that the company does not already hold an LEI from an earlier bank request.
2. Choose an issuer accredited for India. LEIL is the one RBI names. GLEIF also lists registration agents that work with issuers.
3. Register on the issuer's portal and enter Level 1 data exactly as it appears on the certificate of incorporation.
4. Upload the supporting documents and pay the fee.
5. Report Level 2 data on the direct and ultimate parent, or give the reason for not reporting it.
6. Respond to any validation query from the issuer.
7. Download the LEI certificate and confirm the record on the GLEIF database.

In our practice, issuers ask an Indian company for the documents below. Check the issuer's own list before you start, because portals change.

| Document | Why the issuer needs it | Tip for a foreign owned subsidiary |
|---|---|---|
| Certificate of incorporation with CIN | Proves legal name, registration number and date | Match the name exactly, including "Private Limited" in full |
| PAN of the company | Indian registration identifier | Use the company PAN, not a director's |
| Authorisation letter or board resolution | Shows the applicant may act for the company | A director in India can sign; the parent need not |
| Registered office proof | Confirms the legal address | Use the address on the MCA master data |
| Parent company details | Level 2 relationship data | Give the parent's LEI if it has one |

The parent detail is where foreign owned subsidiaries get stuck. If the parent holds an LEI, quote it, and the record links the two. If it does not, the issuer may accept an exception reason. Ask the parent's treasury whether a group LEI exists before you apply.

## How much does an LEI cost in India?

An LEI has an initial registration fee and an annual maintenance fee. GLEIF says "the level of the fees is entirely a matter of" each issuer, so the price depends on the issuer. LEIL publishes its own fee schedule on its portal. We state no rupee figure because fees change and registration agents add their own charges. Before you pay any issuer or agent, ask for the total for the term you want, with GST shown separately.

GLEIF's [questions and answers page](https://www.gleif.org/en/about-lei/questions-and-answers) sets out who pays:

- An entity that registers itself pays the fee.
- A party that registers an unrelated entity pays and decides whether to seek reimbursement.

Some issuers and registration agents sell multi year renewal packages. Compare the total cost over the years you need the code, beyond the first year. Whatever you pay, budget for the renewal every year, because a lapsed LEI is useless to an Indian bank.

## How long is an LEI valid and how is renewal done?

An LEI must be renewed every year. The holder pays the annual maintenance fee and confirms its reference data with the issuer. An LEI that is not renewed shows as lapsed. RBI's 29 Nov 2018 directions say lapsed LEI codes "shall be deemed invalid" for transactions in markets RBI regulates.

The code itself does not expire or change. Only its registration status does. A company that lets the LEI lapse keeps the same code, and renewal brings the status back to issued.

A lapsed LEI causes real problems:

- The AD bank validates the LEI against the GLEIF database under the 10 Dec 2021 circular. A lapsed record can stop a large remittance on the day.
- A lender under the borrower circular cannot renew or enhance a limit for a borrower without a valid LEI.
- A treasury deal of USD 1 million or more can be refused.

Renew before the anniversary date shown on the LEI certificate. We put the renewal date in the subsidiary's [compliance calendar](/insights/compliance-calendar-foreign-owned-company-india-2026-27) next to the DIR-3 KYC and FLA return dates.

Renewal also means updating the data. If the subsidiary moves its registered office, changes its name or gets a new parent after a group restructure, update the LEI record. A stale record can fail the bank's validation even when the status shows issued.

## Where does the LEI appear in remittance paperwork?

The LEI goes wherever the bank or system asks for it. That includes the bank's outward remittance application, the RTGS or NEFT message, the LC or guarantee request, and the bank's own FEMA reporting. RBI prescribes no SWIFT field for it. ITR-6 also asks for it where the refund claimed is INR 50 crore or more.

| Document or system | Where the LEI appears | Source of the requirement |
|---|---|---|
| Bank's outward remittance application (the A2 form and the bank's request letter) | LEI field or declaration in the bank's format | A.P. (DIR Series) Circular No. 20 of 10 Dec 2021; banks set their own format |
| Inward remittance for share subscription or ECB | Bank asks for the Indian company's LEI before credit if INR 50 crore or more | Same circular, which covers capital account receipts |
| RTGS customer payment | "Remittance information" field | DPSS circular of 5 Jan 2021, annex |
| NEFT outward debit | "Sender to Receiver Information" field | DPSS circular of 5 Jan 2021, annex |
| Letter of credit or guarantee request | Checked when the bank issues the instrument | RBI FAQ of 7 Feb 2023 |
| Forex deal confirmation of USD 1 million or more | Client LEI captured by the dealing bank | RBI directions of 29 Nov 2018 |
| Income tax return ITR-6 (AY 2026-27), Part A General | LEI, "mandatory if refund is 50 Crores or more" | [ITR-6 form for AY 2026-27](https://www.incometaxindia.gov.in/documents/d/guest/itr-6-2026-eng-1-pdf), item (r) |

The income tax remittance forms are separate. For money remitted from 1 Apr 2026, the company files Form 145 (old Form 15CA) and, where needed, Form 146 (old Form 15CB). Our guide to [Forms 145 and 146](/insights/form-15ca-and-15cb-requirements-guide-2026) covers them. The bank's remittance application also carries a purpose code, which our [purpose code guide](/insights/purpose-codes-for-foreign-remittance-india) explains. The return itself is covered in our [ITR-6 guide](/insights/itr-6-for-foreign-owned-company).

## Does the foreign parent need an LEI too?

The Indian rule does not require the foreign parent to hold an LEI before your bank pays it. Paragraph 2 of RBI's 10 Dec 2021 circular lets banks process a transaction where the non resident counterparty has no LEI. The parent may still need one under its home rules, and its LEI improves your Level 2 data.

There are three cases where the parent's LEI does matter in India:

- The parent trades in Indian government securities, money markets or forex directly. The 29 Nov 2018 directions require non resident participants to hold an LEI.
- The parent enters an OTC derivative with an Indian bank.
- The subsidiary reports Level 2 data. A parent LEI lets the issuer link the records.

Many parents already hold an LEI for derivative reporting in their home market. Ask before either side pays for a new one.

## What changed in 2026

Nothing changed in the LEI thresholds in 2026. On 23 Oct 2026, INR 50 crore still applies to FEMA transactions and to RTGS and NEFT. INR 5 crore applies to borrowers and USD 1 million to client forex deals. The surrounding FEMA rules did change, and none of those changes removed the LEI requirement.

| Date | Instrument | What changed | Effect on the LEI rule |
|---|---|---|---|
| 6 Jan 2026 | Foreign Exchange Management (Guarantees) Regulations, 2026, FEMA 8(R)/2026-RB | New guarantee framework, Form GRN from 1 Apr 2026 | None stated; RBI's FAQ still requires LEI checks when a guarantee is issued |
| 13 Jan 2026 | Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, FEMA 23(R)/2026-RB | New export and import rules, in force 1 Oct 2026 | The regulations do not mention the LEI |
| 16 Jan 2026 | A.P. (DIR Series) Circular No. 20 of 2026 | Superseded the Master Directions on export and import, and 167 circulars in two annexes (96 export, 71 import), from 1 Oct 2026 | The circular does not mention the LEI |
| Mar 2026 | ITR-6 for AY 2026-27, published by the Income Tax Department | New return form | LEI field kept for refunds of INR 50 crore or more |
| 24 Jun 2026 | A.P. (DIR Series) Circular No. 18 of 2026 | Withdrew 732 FEMA circulars listed in its annex, issued between 2000 and 2023 | The annex has no entry for the LEI circular of 10 Dec 2021 or any other LEI circular on our reading |
| 8 Sep 2026 | A.P. (DIR Series) Circular No. 21 of 2026 | Withdrew seven A.P. (DIR Series) circulars of 2012 to 2015 | The LEI circular is not one of them |

The RBI site still carries the 10 Dec 2021 circular and its FAQ on 23 Oct 2026. Two circulars share the same number. A.P. (DIR Series) Circular No. 20 of 2021 is the LEI rule, and Circular No. 20 of 2026 is the export and import circular.

## Worked example

Take a hypothetical Indian subsidiary of a US parent. It has a working capital limit of INR 4 crore and a bank guarantee limit of INR 2 crore with one bank. In the year it plans a dividend and three import payments. We use an assumed rate of INR 88 to USD 1 for the arithmetic only.

1. Borrower rule. Aggregate exposure is the higher of sanctioned limits and outstanding. Sanctioned limits are INR 4 crore plus INR 2 crore, or INR 6 crore. That is above INR 5 crore, so the bank needs an LEI before it renews either limit.
2. Dividend. The board declares a dividend of INR 62 crore to the parent, paid in one remittance. INR 62 crore is above INR 50 crore, so the FEMA circular applies. Converted at INR 88, the payment is about USD 7,045,455 (620,000,000 ÷ 88). That is above USD 1 million, so the 2018 forex rule applies to the conversion too.
3. Import payments. Each import payment is USD 2 million, or INR 17.6 crore (2,000,000 × 88 = 17,60,00,000). Each is below INR 50 crore, so the FEMA circular does not apply on its own. Each conversion is above USD 1 million, so on our reading the bank needs an LEI for the forex deal.
4. After the LEI is issued. The company now holds an LEI. Under the FEMA circular, its bank reports the LEI on every cross border transaction, including a USD 20,000 software subscription.

| Transaction | Amount | FEMA circular (INR 50 crore) | Forex rule (USD 1 million) | Borrower rule (INR 5 crore) |
|---|---|---|---|---|
| Working capital and guarantee limits | INR 6 crore sanctioned | Not a FEMA transaction | Not a forex deal | Applies |
| Dividend to parent | INR 62 crore, about USD 7.05 million | Applies | Applies | Not relevant |
| Each import payment | USD 2 million, INR 17.6 crore | Below threshold | Applies on our reading | Not relevant |
| Software subscription after LEI issue | USD 20,000 | LEI reported because the company holds one | Below threshold | Not relevant |

The result is simple. This subsidiary needed an LEI from the day its limits crossed INR 5 crore, long before the dividend. Most foreign owned subsidiaries with any bank credit are in the same position.

## Common mistakes

1. **Waiting for the INR 50 crore payment.** The borrower and forex rules usually bite first. Fix: check your sanctioned limits and forex deal sizes now, and get the LEI before the first trigger.
2. **Letting the LEI lapse.** A lapsed LEI is invalid for RBI regulated transactions. Fix: diarise the renewal date a month early and pay the annual fee on time.
3. **Splitting a large remittance to stay under INR 50 crore.** It invites questions and often still meets the USD 1 million forex line. Fix: get the LEI and remit in one payment.
4. **Name mismatch with MCA records.** A shortened legal name in the LEI record that differs from the MCA name can fail the bank's checks. Fix: copy the name from the certificate of incorporation, with "Private Limited" in full.
5. **Not updating the record after a change.** A new registered office, name or parent leaves the LEI data stale. Fix: update the LEI record within the same month as the MCA filing.
6. **Assuming the foreign parent must have an LEI first.** RBI lets banks proceed without the non resident party's LEI. Fix: get the subsidiary's own LEI and ask the parent only for its LEI number, if one exists.
7. **Confusing the two Circulars No. 20.** The 2021 circular is the LEI rule; the 2026 circular is about export and import. Fix: quote the year with the number in any letter to the bank.

To check which LEI rules apply to your subsidiary, send the bank sanction letter and planned remittances through our [FEMA compliance service](/services/fema-compliances.html).

## LEI checklist for an Indian subsidiary

1. Search the GLEIF database for an existing LEI in the company's name.
2. List every sanctioned credit and guarantee limit, and total them against INR 5 crore.
3. List planned cross border transactions of INR 50 crore or more, in either direction.
4. Check whether any forex conversion will be USD 1 million or more.
5. Ask the parent's treasury for the group LEI and the ultimate parent's LEI.
6. Apply to LEIL or another GLEIF accredited issuer with the incorporation, PAN and authorisation documents.
7. Report Level 2 parent data, or record the exception reason.
8. Send the LEI certificate to every bank that holds an account or limit.
9. Quote the LEI on each remittance application, LC request and large RTGS payment.
10. Diarise the annual renewal date and renew before it.
11. Update the LEI record after any change of name, address or parent.

For the remittances themselves, see our guides on [dividends to a foreign parent](/insights/dividend-from-indian-subsidiary-to-foreign-parent) and [ECB from a foreign parent](/insights/ecb-loan-from-foreign-parent-india). Trade payments are covered in [advance remittance for imports](/insights/advance-remittance-for-imports-fema-rules) and the [export realisation period](/insights/export-proceeds-realisation-period-fema). Large share subscriptions also need the [FC-GPR filing](/insights/fc-gpr-filing-timeline-and-process-for-foreign-founders) within 30 days of allotment.

## Key terms

- **Legal Entity Identifier (LEI)**: A 20 character alphanumeric code under the ISO 17442 standard that identifies one legal entity in financial transactions worldwide. In India, RBI directions require it for large cross border transactions under FEMA, large borrowers, OTC derivatives, money and forex markets, and RTGS or NEFT payments of INR 50 crore or more. (https://krystal7.com/glossary#legal-entity-identifier)
- **Local Operating Unit (LOU)**: An organisation accredited by the Global Legal Entity Identifier Foundation to issue and renew LEIs. RBI circulars let Indian entities obtain an LEI from any accredited LOU. GLEIF now calls these organisations LEI issuers. (https://krystal7.com/glossary#local-operating-unit)
- **Legal Entity Identifier India Limited (LEIL)**: The LEI issuer in India that RBI recognises as an issuer under the Payment and Settlement Systems Act, 2007. RBI's directions name it as the Indian source of LEIs, and it issues and renews LEIs for Indian entities. (https://krystal7.com/glossary#legal-entity-identifier-india-limited)
- **Global Legal Entity Identifier Foundation (GLEIF)**: The not for profit body that runs the Global LEI System, accredits LEI issuers and publishes the public LEI database. Indian AD banks validate the LEIs their customers quote against this database, as RBI's 10 Dec 2021 circular requires. (https://krystal7.com/glossary#global-legal-entity-identifier-foundation)
- **Authorised Dealer (AD) Category I bank**: An AD Category I bank is a commercial bank that the Reserve Bank of India authorises under section 10 of FEMA, 1999 to deal in foreign exchange for current and capital account transactions. It receives FDI and export proceeds, checks FEMA filings such as FC-GPR before they reach RBI, holds EEFC accounts and approves most branch and liaison office applications. (https://krystal7.com/glossary#authorised-dealer-category-i-bank)
- **Level 2 data (LEI)**: The relationship data in the Global LEI System that records who owns whom, meaning an entity's direct and ultimate accounting parent. A foreign owned Indian subsidiary reports its parent here when it registers its LEI and keeps it current, or gives a reason for not reporting. (https://krystal7.com/glossary#level-2-data)
- **Over the counter (OTC) derivative**: A derivative contract, such as a forex forward, currency swap or interest rate swap, that two parties agree directly instead of on an exchange. RBI has required non individual participants in OTC rupee interest rate, foreign currency and credit derivatives to hold an LEI since its 1 Jun 2017 circular. (https://krystal7.com/glossary#over-the-counter-derivative)

## Frequently Asked Questions

### Is an LEI mandatory for cross border transactions in India?

Yes, for a resident non individual entity whose single capital or current account transaction under FEMA is INR 50 crore or more. RBI A.P. (DIR Series) Circular No. 20 of 10 Dec 2021 has required it since 1 Oct 2022. The AD bank must obtain the LEI before processing the transaction and must validate it against the GLEIF database.

### Is the INR 50 crore LEI threshold per transaction or per year?

It is per transaction. RBI's 10 Dec 2021 circular applies to capital or current account transactions of INR 50 crore and above per transaction. A company making many smaller payments is not caught by this circular alone. Once it holds an LEI for any reason, the bank must report the LEI on all its transactions.

### Does an Indian company need an LEI for transactions below INR 50 crore?

Not under the FEMA circular alone. Other RBI rules can still require one. A borrower with aggregate exposure of INR 5 crore needs an LEI under the 21 Apr 2022 circular. A client forex deal of USD 1 million or more needs one under the 29 Nov 2018 directions. Once issued, the LEI goes on every remittance.

### Does the foreign parent need an LEI for a remittance from India?

No. Paragraph 2 of the 10 Dec 2021 circular lets the AD bank process the transaction where the non resident counterparty has no LEI. The parent needs its own LEI only if it trades directly in Indian money, government securities or forex markets. An OTC derivative with an Indian bank also needs one.

### What is the LEI requirement for bank borrowers in India?

Non individual borrowers with aggregate exposure of INR 5 crore or more from banks, financial institutions, urban cooperative banks and NBFCs must hold an LEI. RBI's circular of 21 Apr 2022 set this, with final deadlines by 30 Apr 2025. Without an LEI, the lender cannot sanction new exposure or renew or enhance an existing limit.

### Do forex forward contracts need an LEI?

Yes. A forex forward or currency swap is an OTC foreign currency derivative. RBI's circular of 1 Jun 2017 (FMRD.FMID No. 14/11.01.007/2016-17) phased in the LEI for non individual participants in these markets. A company that hedges with its bank must hold a valid LEI, and RBI treats a lapsed LEI as invalid.

### Is an LEI needed for RTGS and NEFT payments?

Yes, for payments of INR 50 crore or more by non individual entities. RBI's DPSS circular of 5 Jan 2021 has required this since 1 Apr 2021. Banks put both parties' LEIs in the RTGS "Remittance information" field or the NEFT "Sender to Receiver Information" field. They also keep records of these payments.

### Who issues LEI codes in India?

Legal Entity Identifier India Limited (LEIL) issues LEIs in India. RBI recognises it as an LEI issuer under the Payment and Settlement Systems Act, 2007. RBI circulars also let Indian entities use any other issuer accredited by the Global Legal Entity Identifier Foundation for India. The code is the same whichever issuer publishes it.

### How much does LEI registration cost in India?

Each issuer sets its own fee, as GLEIF states. An LEI carries an initial registration fee and an annual maintenance fee. LEIL publishes its fee schedule on its portal, and other issuers price differently. Compare the total cost over several years, because renewal is due every year for as long as the company needs the code.

### How often must an LEI be renewed?

Every year. The holder pays the annual maintenance fee and confirms its reference data with the issuer. An LEI that is not renewed shows a lapsed status in the GLEIF database. RBI's 29 Nov 2018 directions deem lapsed LEI codes invalid for transactions in RBI regulated markets, so banks can refuse them.

### What happens if my LEI lapses?

The code stays the same, but its status changes to lapsed. Your AD bank validates LEIs against the GLEIF database, so a large remittance can stop. A lender cannot renew or enhance your limits under the borrower circular. Renew with your issuer, confirm the status shows issued again, and then resubmit the transaction.

### Does the RBI prescribe a SWIFT field for the LEI?

No. RBI's FAQ of 7 Feb 2023 on the cross border circular says it prescribes no instructions on SWIFT message formats. Each bank decides how it captures and carries the LEI. In practice, the bank asks for it on its outward remittance application or customer request letter.

### Do letters of credit and bank guarantees need an LEI?

RBI's FAQ of 7 Feb 2023 covers non fund facilities such as letters of credit and guarantees. It says banks must ensure compliance with the LEI requirements at the issuance stage itself. So the bank checks the LEI when it issues the instrument, before any payment. Ask your bank whether your facility size or an existing LEI triggers the check.

### Does an LLP or a partnership firm need an LEI?

Yes, if it crosses any of the thresholds. RBI's rules apply to non individual entities, which include LLPs, partnership firms, trusts and companies. An LLP that receives INR 50 crore of foreign capital in one transaction needs an LEI. So does an LLP that borrows INR 5 crore or more.

### Is an LEI the same as a CIN or PAN?

No. The CIN is the Corporate Identity Number that MCA gives an Indian company, and the PAN is the income tax number. The LEI is a global 20 character code under ISO 17442, published by GLEIF. LEI issuers use the CIN and PAN to verify the company before they issue its LEI.

### Where does the LEI go in the income tax return?

ITR-6 for AY 2026-27 has an LEI field in Part A General. The form marks it "mandatory if refund is 50 Crores or more". A company claiming a smaller refund may leave it blank. We fill it in whenever the company holds an LEI, so the record matches its bank data.

## Sources

- Reserve Bank of India, A.P. (DIR Series) Circular No. 20, RBI/2021-22/137, Introduction of Legal Entity Identifier for Cross border Transactions, 10 Dec 2021, https://rbi.org.in/scripts/BS_CircularIndexDisplay.aspx?Id=12206
- Reserve Bank of India, FAQs on Introduction of Legal Entity Identifier for Cross border Transactions, 7 Feb 2023, https://rbi.org.in/SCRIPTs/FAQView.aspx?Id=154
- Reserve Bank of India, Legal Entity Identifier (LEI) for Borrowers, RBI/2022-23/34, DOR.CRE.REC.28/21.04.048/2022-23, 21 Apr 2022, https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=12301
- Reserve Bank of India, Legal Entity Identifier Code for participation in non derivative markets, RBI/2018-19/83, FMRD.FMID.No.10/11.01.007/2018-19, 29 Nov 2018, https://rbi.org.in/Scripts/NotificationUser.aspx?ID=11424
- Reserve Bank of India, Introduction of Legal Entity Identifier for Large Value Transactions in Centralised Payment Systems, RBI/2020-21/82, DPSS.CO.OD No.901/06.24.001/2020-21, 5 Jan 2021, https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=12010
- Reserve Bank of India, A.P. (DIR Series) Circular No. 20, RBI/2025-26/194, Export and Import of Goods and Services, 16 Jan 2026, https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13278&Mode=0
- Reserve Bank of India, Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, FEMA 23(R)/2026-RB, 13 Jan 2026, amended up to 22 Sep 2026, https://www.rbi.org.in/Scripts/BS_FemaNotifications.aspx?Id=13277
- Reserve Bank of India, A.P. (DIR Series) Circular No. 18, RBI/2026-27/175, Review of Circulars issued under FEMA, 24 Jun 2026, https://www.rbi.org.in/scripts/NotificationUser.aspx?Id=13551&Mode=0
- Reserve Bank of India, A.P. (DIR Series) Circular No. 21, RBI/2026-27/254, Review of Circulars issued under FEMA, 8 Sep 2026, https://www.rbi.org.in/scripts/NotificationUser.aspx?Id=13696&Mode=0
- Reserve Bank of India, Foreign Exchange Management (Guarantees) Regulations, 2026, FEMA 8(R)/2026-RB, 6 Jan 2026, https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13269&Mode=0
- Global Legal Entity Identifier Foundation, Introducing the Legal Entity Identifier (LEI), read 23 Oct 2026, https://www.gleif.org/en/about-lei/introducing-the-legal-entity-identifier-lei
- Global Legal Entity Identifier Foundation, Get an LEI: find LEI issuing organisations, read 23 Oct 2026, https://www.gleif.org/en/about-lei/get-an-lei-find-lei-issuing-organizations
- Global Legal Entity Identifier Foundation, Questions and answers on the LEI, read 23 Oct 2026, https://www.gleif.org/en/about-lei/questions-and-answers
- Income Tax Department, Form ITR-6 for AY 2026-27, https://www.incometaxindia.gov.in/documents/d/guest/itr-6-2026-eng-1-pdf
- Reserve Bank of India, Annex to A.P. (DIR Series) Circular No. 18 of 24 Jun 2026 (732 circulars withdrawn), https://rbidocs.rbi.org.in/rdocs/content/pdfs/APDIR1824062026.pdf
- Reserve Bank of India, Draft Directions for regulated entities, Commercial Banks Credit Risk Management Directions, 2025 (draft), Chapter VII, https://rbi.org.in/scripts/BS_ViewREwiseDraftDirections.aspx?id=12
- Reserve Bank of India, Commercial Banks Credit Risk Management Directions, 2025 (updated as on 1 Oct 2026), https://www.rbi.org.in/scripts/BS_ViewMasDirections.aspx?id=13153
- Global Legal Entity Identifier Foundation, Level 2 data: who owns whom, read 23 Oct 2026, https://www.gleif.org/en/lei-data/access-and-use-lei-data/level-2-data-who-owns-whom

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