On 20 December 2017, the European Securities and Markets Authority (ESMA) issued a statement which provided for trading venues to report their own legal identity identifier (LEI) codes instead of LEI codes of non-EU issuers that do not have their own LEI codes. In addition, the statement envisaged a possibility for investment firms to provide a service triggering the obligation to submit a transaction report to the client, from which it did not previously obtain an LEI code, under the condition that before providing such service the investment firm obtains the necessary documentation from this client to apply for an LEI code on his behalf. This also required Member State national competent authorities to temporarily amend a validation rule in their transaction reporting systems to allow for the acceptance of transaction reports where the LEI issuance date is after the transaction execution date.

Since 20 December 2017, ESMA has observed a significant increase in the LEI coverage for both issuers and clients. In light of this it issued on 20 June 2018 a press release stating that there is no need to extend the initial six month period granted to support the smooth introduction of the LEI requirements under MiFIR. The period will last until 2 July 2018, inclusive.