HomeCirculars › RBI/2022-23/34

LEI Mandate Extended to UCBs, NBFCs; New Timelines for Borrowers

No longer current — withdrawn, no replacement on file yet
Source: Reserve Bank of India · RBI/2022-23/34 · issued 21 Apr 2022 · ~2 min read
Quick answerRBI extends LEI requirement to UCBs and NBFCs. Non-individual borrowers with aggregate exposure of ₹5 crore and above must obtain LEI codes by phased deadlines from April 2023 to April 2025, or face restrictions on new credit.

What changed

The LEI mandate, previously applicable only to banks and FIs, now covers Primary (Urban) Co-operative Banks and NBFCs. A phased timeline is introduced: borrowers with exposure above ₹25 crore need LEI by April 30, 2023; ₹10-25 crore by April 30, 2024; and ₹5-10 crore by April 30, 2025.

What it means for you

Lenders must update their systems to track LEI compliance for all non-individual borrowers with aggregate exposure of ₹5 crore and above, including fund and non-fund based exposure. Failure by borrowers to obtain LEI will block new sanctions, renewals, or enhancements, except for central/state government agencies. This tightens credit discipline and enhances transparency in large exposures.

Historical instruction — do not use for current compliance. This is what was required at the time; it no longer reflects current RBI requirements. If no replacement rule is linked above, that only means none is recorded on our register yet — it does not prove no later applicable rule exists. Confirm on the official RBI source below.

What banks were required to do at the time

Who it affects

Scheduled Commercial Banks (excluding RRBs), All India Financial Institutions, Small Finance Banks, Local Area Banks, Primary (Urban) Co-operative Banks, Non-Banking Financial Companies (including HFCs)

❓ Common questions

Regulatory timeline

Built from our lineage records — each fact carries its provenance; missing history simply is not shown (never guessed).

What is the definition of 'exposure' for LEI purposes?

Exposure includes all fund-based and non-fund-based credit and investment exposure. The aggregate sanctioned limit or outstanding balance, whichever is higher, is considered.

What happens if a borrower fails to obtain LEI by the deadline?

Lenders must not sanction any new exposure, renewal, or enhancement of existing exposure for such borrowers. Central and state government agencies are exempt from this restriction.

Are existing borrowers with exposure below ₹5 crore affected?

No, the mandate applies only to non-individual borrowers with aggregate exposure of ₹5 crore and above. Lower exposures are not covered.

📜 This document’s life story (1 recorded event, each backed by RBI’s own words)
Repealed by RBI/2025-26/100 — Consolidation of Regulations — Withdrawal of circulars (28 Nov 2025)
RBI’s words: “Official withdrawal register entry #244: DOR.CRE.REC.28/21.04.048/2022-23 — "Legal Entity Identifier (LEI) for Borrowers" dated April 21, 2022”
📜 Read the original circular — full text as issued by RBI
Notifications - Reserve Bank of India Skip to main content Selected Selected Change Language हिंदी Search the Website Search Home About Us ▼ About Us Organisation & Functions ▶ Organisation Structure Departments Offices Training Establishment ▶ College of Agricultural Banking Reserve Bank Staff College College of Supervisors RBI's Functions and Working Governors Deputy Governors Executive Directors Communication Policy of RBI Sources of Information ▶ Annual Publications Half-yearly Publications Quarterly Publications Monthly Publications Weekly Publications Occasional Publications SDDS NSDP Data Releases Publications available on Subscription General Information RBI History Museum ▶ The RBI Museum RBI Monetary Museum Notification ▼ Notifications Master Directions Master Circulars Amendment Directions Draft Notifications/Guidelines ▶ Draft Notifications/Guidelines Draft Directions (RE-wise) Index To RBI Circulars Standalone Circulars Circulars Withdrawn Press Releases Speeches & Media Interactions ▼ Speeches Media Interactions Memorial Lectures Podcasts Publications ▼ Biennial Annual Half-Yearly Quarterly Bi-monthly Monthly Weekly Occasional Reports Working Papers Legal Framework ▼ Act Rules Regulations Schemes Research ▼ External Research Schemes RBI Occasional Papers Working Papers RBI Bulletin History DRG Studies KLEMS State Statistics and Finances Statistics ▼ Data Releases Database on Indian Economy Public Debt Statistics Regulatory Reporting ▼ List of Returns Data Definition Validation rules/ Taxonomy List of RBI Reporting Portals FAQs of RBI Reporting Portals Home Notifications Notifications ( 846 kb ) Legal Entity Identifier (LEI) for Borrowers RBI/2022-23/34 DOR.CRE.REC.28/21.04.048/2022-23 April 21, 2022 All Scheduled Commercial Banks (Excluding Regional Rural Banks), All India Financial Institutions, Small Finance Banks, Local Area Banks, Primary (Urban) Co-operative Banks, and Non-Banking Financial Companies (including Housing Finance Companies) Madam/Dear Sir, Legal Entity Identifier (LEI) for Borrowers Please refer to Para 3 of DBR.No.BP.BC.92/21.04.048/2017-18 dated November 2, 2017 , on the captioned subject. 2. On a review, it has been decided that the guidelines on LEI stand extended to Primary (Urban) Co-operative Banks (UCBs) and Non-Banking Financial Companies (NBFCs). It is further advised that non-individual borrowers enjoying aggregate exposure of ₹5 crore and above from banks 1 and financial institutions (FIs) 2 shall be required to obtain LEI codes as per the timeline given in the Annex . “Exposure” for this purpose shall include all fund based and non-fund based (credit as well as investment) exposure of banks/FIs to the borrower. Aggregate sanctioned limit or outstanding balance, whichever is higher, shall be reckoned for the purpose. Lenders may ascertain the position of aggregate exposure based on information available either with them, or CRILC database or declaration obtained from the borrower. c) Borrowers who fail to obtain LEI codes from an authorized Local Operating Unit (LOU) shall not be sanctioned any new exposure nor shall they be granted renewal/enhancement of any existing exposure. However, Departments/Agencies 3 of Central and State Governments (not Public Sector Undertakings registered under Companies Act or established as Corporation under the relevant statute) shall be exempted from this provision. 3. These directions are issued under sections 21, 35A and 56 of the Banking Regulation Act, 1949, sections 45JA and 45L of the Reserve Bank of India Act, 1934, section 30A of the National Housing Bank Act, 1987 and section 6 of the Factoring Regulation Act, 2011. Yours faithfully, (Manoranjan Mishra) Chief General Manager Annex Timeline for obtaining LEI by borrowers Total Exposure LEI to be obtained on or before Above ₹25 crore April 30, 2023 Above ₹10 crore, up to ₹25 crore April 30, 2024 ₹5 crore and above, up to ₹10 crore April 30, 2025 1 “Banks” shall mean Scheduled Commercial Banks (excluding Regional Rural Banks), Local Area Banks, Small Finance Banks and Primary (Urban) Co-operative Banks 2 “Financial Institutions” (FIs) shall mean All India Financial Institutions (Exim Bank, SIDBI, NHB, NABARD and NaBFID) and NBFCs (including HFCs) 3 A government agency is an administrative set up of the government, responsible for certain area/s of activity, e.g., ISRO, BIS, DGCA, etc. 2026 All Months January February March April May June July August September October November December 2025 All Months January February March April May June July August September October November December 2024 All Months January February March April May June July August September October November December 2023 All Months January February March April May June July August September October November December 2022 All Months January February March April May June July August September October November December 2021 All Months January February March April May June July August September October November December 2020 All Months January February March April May June July August September October November December 2019 All Months January February March April May June July August September October November December 2018 All Months January February March April May June July August September October November December 2017 All Months January February March April May June July August September October November December Archives 2016 All Months January February March April May June July August September October November December 2015 All Months January February March April May June July August September October November December 2014 All Months January February March April May June July August September October November December 2013 All Months January February March April May June July August September October November December 2012 All Months January February March April May June July August September October November December 2011 All Months January February March April May June July August September October November December 2010 All Months January February March April May June July August September October November December 2009 All Months January February March April May June July August September October November December 2008 All Months January February March April May June July August September October November December 2007 All Months January February March April May June July August September October November December 2006 All Months January February March April May June July August September October November December 2005 All Months January February March April May June July August September October November December 2004 All Months January February March April May June July August September October November December 2003 All Months January February March April May June July August September October November December 2002 All Months January February March April May June July August September October November December 2001 All Months January February March April May June July August September October November December 2000 All Months January February March April May June July August September October November December 1999 All Months January February March April May June July August September October November December 1998 All Months January February March April May June July August September October November December 1997 All Months January February March April May June July August September October November December 1996 All Months January February March April May June July August September October November December 1995 All Months January February March April May June July August September October November December 1994 All Months January February March April May June July August September October November December 1993 All Months January February March April May June July August September October November December 1992 All Months January February March April May June July August September October November December 1991 All Months January February March April May June July August September October November December Top Back to previous page More Links Bank Holidays Banking Glossary Citizen's Charter Complaints Contact Us COVID-19 Measures E-LMS Events FAQs Financial Education Forms IFSC/MICR Codes Important Websites Opportunities @ RBI RBI Clarifications RBI Kehta Hai RBI’s Vision and Values (1257 kb)--> Right to Information Act Tenders Follow RBI RSS Twitter YouTube Instagram Facebook LinkedIn © Reserve Bank of India. 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Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2022-23/34 · issued 21 Apr 2022. The plain-English explanation above is BankPulse’s own independent summary.
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