Harun Raaj & AssociatesHarun Raaj & Associates
Business Compliance & Labour Law

LEI & TReDS

LEI & TReDS

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Overview

A Legal Entity Identifier (LEI) is the 20-character global identifier for the entities that transact in the financial markets, issued under the framework of the RBI and the Legal Entity Identifier (LEI) guidelines — required for the participants in the over-the-counter derivatives markets and the large corporate borrowers under the RBI's directions, and increasingly for the entities making high-value cross-border payments under the RBI's instructions. The LEI is obtained from the local operating units (LOUs) accredited by the Global Legal Entity Identifier Foundation, and it identifies the entity uniquely across the markets.

The LEI is the financial identity of the entity in the derivatives and the large-value transaction markets. The RBI has progressively required the LEI for the OTC derivatives counterparties, for the large corporate borrowers, and for the cross-border payments above the prescribed thresholds — VERIFY: the RBI's instructions on the LEI for the cross-border transactions require it for the individual transactions above a notified amount. Without the LEI, the entity cannot participate in the markets that require it.

The cost of the missing LEI is the blocked transaction: the derivatives that cannot be executed, the large-value payment that cannot be processed, the borrowing that the bank cannot service without the identifier. The LEI is cheap and quick; the absence of it stops the transaction at the counter.

This service is for entities that transact in the financial markets — the corporates, the funds, the banks and the NBFCs. We determine the LEI requirement under the RBI's framework, prepare and submit the application to the accredited LOU, manage the renewal and the reference data updates, and maintain the LEI so the entity's market transactions are never blocked for the lack of the identifier.

How It Works

  1. 1

    LEI Requirement Check

    We determine the LEI requirement under the RBI's framework.

    Harun Raaj & Associates does this1-2 days
  2. 2

    LOU & Application Preparation

    We prepare the application with the entity's reference data for the LOU.

    Harun Raaj & Associates does this2-3 days
  3. 3

    Submission & Issuance

    We submit the application and obtain the LEI.

    Harun Raaj & Associates does this1-2 weeks
  4. 4

    Market Integration

    We update the entity's records for the derivatives and the payment transactions.

    Harun Raaj & Associates does this3-5 days
  5. 5

    Renewal & Updates

    We manage the annual renewal and the reference data updates.

    Harun Raaj & Associates does thisAnnual

Frequently Asked Questions

Which entities in India are mandatorily required to obtain a Legal Entity Identifier (LEI)?
The Reserve Bank of India has progressively mandated LEI for large-value financial transactions. All entities (other than individuals) participating in the over-the-counter (OTC) derivatives market, non-derivative markets, and large-value transactions in the Centralised Payment Systems (RTGS/NEFT) above ₹50 crore must hold an LEI as per RBI circular RBI/2018-19/95 (October 2018) and subsequent circulars. Companies availing of bank credit above ₹5 crore are required to obtain LEI under RBI/2020-21/76 issued by the Department of Regulation. SEBI has separately mandated LEI for FPIs, mutual funds, and large corporates issuing debt securities via SEBI circular SEBI/HO/DDHS/CIR/P/2022 dated March 2022. LEI is obtained through Legal Entity Identifier India Limited (LEIL), a subsidiary of the Clearing Corporation of India Limited (CCIL), and must be renewed annually.
What documents are required for LEI registration and how long does the process take?
To obtain an LEI from LEIL (Legal Entity Identifier India Limited), an entity must submit its Certificate of Incorporation, Memorandum and Articles of Association, PAN card, latest audited financial statements, and a list of beneficial owners holding more than 10% per the Global LEI Foundation (GLEIF) guidelines on Level 2 (who-owns-whom) data. For LLPs, the LLP Agreement and Certificate of Registration from MCA are substituted for MOA/AOA. The application is filed online at the LEIL portal (lei.org.in) and LEIL typically issues the 20-character alphanumeric LEI code within 3-5 working days after document verification. The LEI must be renewed annually by submitting updated financial statements and confirming that beneficial ownership data remains current, as GLEIF requires all published LEI records to reflect current information under the GLEIF data quality guidelines.
What is TReDS and which categories of sellers and buyers can participate on the platform?
TReDS (Trade Receivables Discounting System) is an electronic platform authorised by the RBI under the Payment and Settlement Systems Act 2007 (Section 4) for facilitating the financing of trade receivables of Micro, Small and Medium Enterprises (MSMEs) through multiple financiers. Sellers eligible to upload invoices on TReDS must be MSMEs registered under the MSME Development Act 2006 (Udyam Registration), while buyers can be any corporate, PSU, or government entity irrespective of size. The RBI mandated all companies with a turnover above ₹500 crore and all CPSEs and government departments to register on at least one TReDS platform per RBI circular RBI/2019-20/130 dated November 2019. The three SEBI/RBI-authorised TReDS platforms are Receivables Exchange of India Limited (RXIL), M1xchange (Mynd Solutions), and Invoicemart (A.TREDS Limited).
How are TReDS discounting proceeds and charges treated for GST and Income Tax purposes?
Under GST, factoring or invoice discounting through TReDS constitutes a 'financial service' provided by the financier (bank or NBFC) to the MSME seller; such services are exempt from GST under Entry 27 of Notification No. 12/2017-Central Tax (Rate) dated June 28, 2017, as they are in the nature of extending deposits, loans, or advances. From the MSME seller's perspective, the invoice uploaded on TReDS represents a supply already subject to GST when raised on the buyer; the discounting charge paid to the financier is an input service expense deductible under Section 37(1) of the Income Tax Act 1961 as a business expenditure for AY 2026-27. The buyer makes payment on the due date directly to the financier and must deduct TDS under Section 194A only if the discounting charge is separately billed as 'interest' — if embedded in the purchase price, no TDS is required. Gains from early payment by the financier are not capital gains but are revenue receipts of the MSME.
Can an MSME claim a deduction for interest on delayed payment by buyers, and how does TReDS interaction affect this?
Under Section 16 of the MSME Development Act 2006, if a buyer fails to pay an MSME within the agreed period (not exceeding 45 days under Section 15), compound interest at three times the bank rate notified by the RBI becomes payable. From the buyer's tax perspective, such interest is not deductible as a business expense under Section 23 of the MSME Development Act 2006, which was re-confirmed in the CBDT clarification and by the insertion of Section 43B(h) of the Income Tax Act 1961 (effective from AY 2024-25 onwards) — payments to MSMEs beyond the prescribed period are disallowed in the year of accrual and allowed only in the year of actual payment. TReDS effectively eliminates delayed payment risk for the MSME seller because the financier pays the MSME immediately upon buyer acceptance of the invoice; the buyer's liability shifts to the financier on the due date, removing the Section 43B(h) disallowance risk for the buyer and the delayed-payment interest risk for the MSME.

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