Do Charities Need an LEI? UK Compliance Guide 2025

Tech Admin October 13, 2025 0 Comments

Do Charities Need an LEI? UK Compliance Guide 2025

Understanding the compliance landscape: do charities need an LEI? Clarity on which organisations may need one helps in deciding.

A growing number of UK charities are being asked for a Legal Entity Identifier by their investment managers and banks. Some have already run into the red flag that stops trades when an LEI is missing. Others are unsure whether the rules apply to them at all.

Clarity helps. So does a simple way to act when needed.

Table of Contents

What an LEI is, and why the request keeps coming up

The LEI is a 20‑character code that uniquely identifies a legal entity in financial markets. Regulators use LEIs to keep transaction reporting accurate and to reduce confusion when similar names appear across instruments, countries and corporate registers.

In the UK, rules based on MiFIR and EMIR require an LEI when an entity trades listed securities or enters into derivatives. The principle is well known to brokers and asset managers: no LEI, no trade.

That framework applies in 2025 just as it did in previous years, now sitting in UK regulation under the FCA and the Bank of England. If a charity is the counterparty for a reportable transaction, the LEI is expected.

Which types of charity may need one

Whether an LEI is required depends less on charitable status, and more on the activities and structure.

Charitable companies limited by guarantee that trade securities through a broker need an LEI
Charitable Incorporated Organisations usually need one when opening a discretionary or execution‑only account for listed instruments
Charitable trusts need an LEI when the trust itself enters derivatives or trades reportable securities, even when trustees act on its behalf
Unincorporated charities that invest only through a pooled fund where the manager is the counterparty often do not need an LEI, although some platforms still request one during onboarding

A simple rule of thumb: if the charity will appear as the client on a broker’s order book or as a counterparty to a derivative, an LEI is almost always required.

Common scenarios for 2025

Here are typical situations UK charities may face in 2025 regarding LEI requirements:

Buying or selling listed shares, gilts, or corporate bonds in the charity’s name requires an LEI for regulatory reporting.
Using a discretionary investment manager with a segregated account also requires an LEI, as trades are reported against the charity.
No LEI is needed if the charity only holds cash deposits, processes Gift Aid, or makes grants without traded investments.
Investing solely in pooled vehicles (like OEICs or unit trusts) often does not require an LEI, but some fund managers may still request one—check their policy.
FX spot transactions usually do not require an LEI, but FX forwards, options, and other derivatives do.
Entering into interest rate swaps, currency hedges, or any derivatives requires an LEI.
If a platform mandates an LEI, the charity must obtain one, regardless of the investment type.

If unsure, always ask your broker or investment manager, as they are responsible for compliance and can advise on LEI requirements. LEI.

What this means for trustees and finance teams

Trustees carry primary responsibility for compliance. Where investments are part of the charity’s strategy, the board should treat the LEI as an operational requirement alongside bank mandates, KYC and investment policy statements.

Practical points:

Obtain an LEI before the first trade or switch to avoid delays
Keep the LEI renewed each year so the status remains active, as some firms will block trades on a lapsed LEI
Nominate a responsible officer or the company secretary to hold the renewal reminders
For charities with multiple investment relationships, share the LEI across providers to prevent repeated requests

Timing matters. New managers often set a tight onboarding window, and hitting a pause because the LEI has expired can be frustrating.

How to get an LEI for a UK charity

The process is simple with an accredited agent. At LEI Service, applications take about a minute and are linked to public registers for speed. Most LEIs are issued in 10 minutes to 48 hours. A VIP option is available for time‑sensitive cases, typically within two hours when submitted before 5pm on business days.

What you will need:

The charity’s legal name and registered address
Registration numbers, for example Charity Commission or Companies House, if applicable
For trusts, the trust name and basic deed details
A named authorised person, such as a trustee, director or officer

Validation pulls from authoritative sources. For charitable companies, Companies House records are matched. For CIOs and registered charities, Charity Commission data is used. Trusts are assessed under GLEIF rules for legal arrangements.

What about charities that only invest through pooled funds

This is a common point of confusion. If your charity invests only in pooled funds where the fund manager is the counterparty for market trades, the manager uses its own LEI for those transactions. In that case an LEI might not be strictly required for regulatory reporting.

Two caveats apply. First, some platforms set an internal policy that every legal entity client must provide an LEI, no exceptions. Second, hedging contracts connected to your account, or certain corporate actions, can trigger LEI use. The simplest approach is to ask your platform for a written confirmation of their requirement. If they require one, obtain it before funding the account.

How LEI Service supports charities

LEI Service is an official registration agent of Ubisecure RapidLEI. Our team has backgrounds in IT, compliance and finance, which helps when a case needs human attention rather than another ticket number.