Source: OJ L, 2025/1140, 10.6.2025

Article 14 Identification of clients that are legal entities

Summary What does Article 14 of the RTS on record keeping say?

This article sets out how crypto-asset service providers must identify their legal entity clients when submitting order and transaction information to competent authorities, as required under Articles 6 and 7.

The core requirement is the use of Legal Entity Identifier (LEI) codes, specifically those compliant with the ISO 17442 standard and listed in the Global LEI database.

Where a client does not hold a compliant LEI, the article provides a fallback route, allowing the use of a Union-level identifier provided it meets a defined set of quality characteristics.

Important points:

When reporting to competent authorities, identify all legal entity clients using an LEI code compliant with ISO 17442 and listed in the Global LEI database.
Where a client lacks a compliant LEI, obtain one for them or use a Union-level identifier that meets the required characteristics.
Any alternative Union-level identifier used must be unique, neutral, reliable, open source, scalable, accessible, available for free or at a reasonable cost, and subject to an appropriate governance framework.

Springlex's summary of the article, a reading aid, not a substitute for the legal text.

1. When providing to the competent authorities the information referred to in Articles 6 and 7, a crypto-asset service provider shall identify any clients that are legal entities by using a legal entity identifier code corresponding to those clients.
1. Crypto-asset service providers shall record the legal entity identifier codes that comply with the ISO 17442 standard and are included in the Global LEI database maintained by the Central Operating Unit appointed by the Legal Entity Identifier Regulatory Oversight Committee.
1. Where the client does not have a legal entity identifier compliant with the ISO 17442 standard, the crypto asset service provider shall obtain one for the client, or use an identifier defined at Union level which meets all of the following characteristics:
  1. is unique;
  2. is neutral;
  3. is reliable;
  4. is open source;
  5. is scalable;
  6. is accessible;
  7. is available for free or at a reasonable cost;
  8. is subject to an appropriate governance framework.

Relevant recitals

Recital 9 Criteria for legal entity client identifiers

To facilitate market surveillance and to allow for the comparability of the records to be kept by crypto-asset service providers, clients of crypto-asset service providers that are legal entities should be identified with a code that is compatible with the internationally established criteria for the development of robust identification systems for the monitoring of financial markets. Such code should be unique, neutral, reliable, open source, scalable, accessible, available for free or at a reasonable cost, and subject to an appropriate governance framework. These criteria were also used by the competent authorities for assessing the most appropriate identifiers in previous technical standards on supervisory data(⁵)(⁶), to ensure consistency and comparability of data on financial transactions, and therefore should also be applicable in the context of this Regulation.

Recital 10 Use and future development of LEI and EUID

LEI is a widely recognised, financially and operationally accessible international identifier used in financial markets. LEI is an international identifier that ensures access to the underlying data at all times, allowing for comparability and aggregation of information at Union level, improving the quality and timeliness of aggregated data and reducing the reporting burden for crypto-asset service providers. Therefore, crypto-asset services providers should, where available, record the LEI of clients that are legal persons on whose behalf they carry out orders and execute transactions. However, there are other legal entity identifiers that may be appropriate for use in the context of this Regulation. Directive (EU) 2017/1132 of the European Parliament and of the Council(⁷) requires companies subject to that Directive to have a European Unique identifier (‘EUID’), which unequivocally identifies companies and as such is an appropriate tool for the identification of entities in the EU. Within a period of 18 months after the entry into force of this Regulation, the Commission and ESMA will work closely to facilitate the use of EUID as a tool to identify clients that are legal entities for the purpose of this Regulation. Following the completion of this work, the Commission should assess the readiness to use EUID for the purposes of Article 14. Additionally, to ensure openness to other identifiers which may be fit for supervisory purposes and support the integrity of the market, this Regulation sets out criteria that should be met by those alternative identifiers. To enable the market to use such eligible alternative identifiers, ESMA should approve their use where they meet the criteria set out in this Regulation.

Recital 11 Harmonised party identification for data-driven monitoring

A unique method for the identification and classification of parties compliant with the above-mentioned criteria and instruments that follow these principles directly supports efforts to achieve data-driven market monitoring by competent authorities.

Table of contents

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