Response to consultation paper on draft Technical Standards on information for authorisation

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Question n. 5: Do you agree with the general content and level of detail of the information to be contained in the application?

The Global Legal Entity Identifier Foundation (GLEIF) welcomes the ongoing work by the EBA on setting out the authorization procedure for entities seeking to issue or trade asset-referenced tokens (ARTs). More importantly, GLEIF supports the introduction of the ISO 17742 LEI in the standard templates to be used for authorization process, as stipulated under article 2(d) of the draft regulatory technical standards.

As a universal, machine-readable, and readily available identifier, the ISO 17442 LEI will increase the transparency of the authorization processes by creating an automated means of identifying applicant entities. Furthermore, the authorization process can evolve over time to leverage the vLEI. The vLEI is the secure digital counterpart of a conventional LEI. It is a digitally trustworthy version of the 20-digit LEI code which is automatically verified, without the need for human intervention. This would significantly enhance the security and straight through processing of the authorization process. In addition, the introduction of the LEI in such process can contribute to a more efficient risk-management framework, as it creates a credible process for knowing ‘who is who’ in the EU ARTs market. For examples, please see The Banque de France publication “An identifier to characterize groups’ global expansion strategies” ( and De Nederlandsche Bank “Measuring intra-bank complexity by (not) connecting the dots with LEI. A supervisor perspective” (

Lastly, the LEI is a standard that facilitates data-sharing and advanced analytics that are necessary for supervisors and public authorities tasked with overseeing potential ML/TF risks (for further information, please consult the Bank of International Settlements’ Project Aurora – the power of data, technology and collaboration to combat money laundering across institutions and borders, June 2023;

Question n. 6: Do you consider that Annex II to the ITS is sufficiently clear in the identi-fication of the information requested for each field and sub-field?

As previously mentioned, the use of the LEI as part of the application procedure has the potential of strengthening the regulatory oversight of the authorization process.

To ensure that the information requested in the template for authorization (Annex II) is clear and consistent, GLEIF recommends the following:

(1) Eliminate the data elements that are duplicative with the LEI reference data – specifically legal name (Article 2(1)(c)) and legal form (Article 2(1), (e) – (g)). This will reduce regulatory reporting burden and fully leverage the globally standardized reference data associated with the LEI. For example, the entity legal form noted in the LEI record conforms to the ISO standard 20275 ‘Financial Services – Entity Legal Forms (ELF)’ ( And the national authority providing the national identification number is a standardized code from the Registration Authorities List (
(2) Introduce a statement clarifying that the LEI must conform with the Regulatory Oversight Committee policies (ROC) ( The ROC was established in November 2012 to coordinate and oversee the Global LEI System. The ROC is composed of more than 65 financial markets regulators and other public authorities including the EBA and ESMA. The inclusion of this statement is a necessary step to ensure the LEI is leveraged in the most efficient manner, most notably by ensuring that the refence data included is regularly updated

Name of the organization

Global Legal Entity Identifier Foundation (GLEIF)