On 7 September 2026, the Global Legal Entity Identifier Foundation (GLEIF) introduced two features of its Data Challenge Facility. Anyone who relies on Legal Entity Identifier data can rate the resolution of a challenge they raised, and resubmit that challenge if the outcome did not settle the issue. Both options stay open for 28 days after a challenge is resolved.
The change adds little to the process itself, but it matters for businesses. Until now, raising a data challenge was effectively a one-way action. You reported a problem in an LEI record, an LEI issuer investigated and the matter closed with whatever answer came back. If that answer missed the point, the only option was to start over with a new challenge that carried none of the original history. That gap is now closed, and it gives companies more influence over how their own public identity data is recorded.
Why the Data in Your LEI Record Matters
An LEI is a 20-character code that identifies a legal entity in financial transactions, but the code itself is only the pointer. Behind it sits a public record in the Global LEI Index, and that record is what banks, regulators, payment providers and business partners actually read.
The record holds two layers of information. Level 1 answers the question of who is who, covering the entity’s legal name, its registered office address, its registration number with the Companies Registration Office (CRO) and its status. Level 2 answers the question of who owns whom, covering direct and ultimate parent relationships, or a recorded reason why a parent is not disclosed. Our overview of the Global Legal Entity Identifier system explains how the system is organised, and our guide to reporting a parent-subsidiary relationship covers what Level 2 reporting requires.
Because the record is public and machine-readable, errors in it travel. A legal name that still shows a company’s pre-merger form, an address that was updated with the CRO but never in the LEI record, or a parent relationship that no longer exists will be picked up by every counterparty that pulls the data. In onboarding and in the Know Your Customer (KYC) checks that banks carry out under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, a mismatch between the LEI record and the documents a company supplies is normally treated as something to resolve before the relationship proceeds, which costs time even when nothing is actually wrong.
What the GLEIF Data Challenge Facility Is
The GLEIF Data Challenge Facility is the mechanism for reporting a problem in LEI reference data, and it is open to everyone. GLEIF states that any interested party can raise a challenge against the data record for any LEI, at any time. That means you can challenge your own record, and you can challenge the record of a counterparty whose published details do not match what you have been given.
The scope is broad. Challenges can cover the accuracy or completeness of legal entity reference data, referential integrity between LEI records, possible duplicate registrations, relationship information including direct and ultimate parent relationships and the exceptions used in place of them, a lack of timely response to corporate actions and questions of LEI eligibility and exclusivity. Evidence can be attached as an uploaded file or entered as text, including links to documents published online.
Once a challenge is submitted, GLEIF passes it to the LEI issuing organisation that maintains the record, and the submitter receives a summary and confirmation by email. The issuer investigates and, where a change is appropriate and supported by verification, updates the LEI data. GLEIF states that the aim is typically to resolve a challenge within 10 working days, so that figure is a target rather than a guaranteed turnaround.
What GLEIF Announced on 7 September 2026
Writing on the GLEIF blog, Zornitsa Manolova, Head of Data Quality Management and Data Science at GLEIF, set out the reasoning behind the update. “High-quality Legal Entity Identifier (LEI) data is a shared effort,” she wrote, describing the facility as a second layer of quality assurance alongside GLEIF’s own data quality program. GLEIF runs automated data quality checks daily against the full published LEI population and publishes monthly data quality reports, but automated checks cannot see everything that an entity, or a counterparty dealing with it, can see.
A recent GLEIF poll on priorities for the facility showed what users felt was missing. A combined 70 per cent of respondents named a clear resolution and an option to resubmit challenges as important areas for improving the overall user experience. The two features answer both of those points, and both are available for 28 days after a challenge is resolved.
Rating a Resolution
When a challenge is resolved, the person who raised it can record feedback directly in the Data Challenge Facility. The rating itself is simple, indicating whether you were satisfied or dissatisfied with the resolution, with an optional comment explaining the rating.
The value of that feedback runs in two directions. A positive rating tells the LEI issuer that the process worked and the matter is settled, which is worth recording rather than leaving implied. A negative rating, especially with a specific comment attached, marks where the resolution or the handling of it fell short, and that is what GLEIF needs to improve the process for everyone. Rating a resolution is quick, and it is the one part of the process where the data user sets the verdict.
Resubmitting a Challenge
The second feature deals with the situation where an answer arrived but the problem did not go away. A resolution does not always mean that every concern has been addressed. The data may have been changed in a way that does not match what you proposed, the explanation may have covered a different field from the one you flagged, or new evidence may have reached you only after the issuer had closed the case.
In that situation you can create a new challenge that carries a copy of the previously challenged fields and the values you proposed for them, add a comment explaining why you are raising the matter again and attach new evidence where you have it. The original challenge and the resubmitted one stay linked. That linkage is the real improvement, because the issuer sees the full history of what was asked and answered rather than an isolated second complaint, and the resubmission reads as a continuation of one issue instead of a fresh dispute.
When a Data Challenge Is the Right Route, and When It Is Not
There is an important distinction that the announcement does not spell out, and getting it wrong costs time. The Data Challenge Facility is a mechanism for challenging a record. It is not the standard mechanism for maintaining your own.
If the error sits in your own LEI record and your LEI is managed by a registration agent, the normal route is a data update. Your agent submits the corrected legal name, address, CRO number or parent information to the accredited issuing organisation together with the supporting evidence, and the record is amended through the ordinary lifecycle process. That route is more direct than a challenge, because the issuer is verifying data supplied by the entity itself rather than investigating a doubt raised against the record. The data arrives through the agent the entity has authorised by signed power of attorney to submit on its behalf.
There are three situations in which a data challenge is the right route.
- The record belongs to another entity, for example a counterparty whose published details do not match the contracts or invoices you hold.
- Your own record is managed elsewhere and the party managing it has not corrected an error you have already reported.
- The problem is structural rather than a routine amendment, such as a duplicate registration for the same entity or a relationship recorded against the wrong parent.
Raising a challenge for something a routine data update would have fixed adds an investigation step that the LEI issuer aims to complete within 10 working days, on top of a change your agent could have submitted directly.
How a Registration Agent Helps
LEI data errors are usually easier to prevent than to correct, and that is where a registration agent earns its place. Our article on why to use an official registration agent when applying for an LEI code explains what else to look at when you choose one. We check the entity’s legal name, registered office address and CRO number against the CRO register before anything is submitted to the issuing organisation, so the record starts out matching the official source rather than matching a form completed from memory.
If your LEI was registered through a registration agent, you can also go to the agent directly whenever the data needs correcting. At LEI Ireland, correcting the data of an LEI that has not lapsed is free of charge for all our customers. What the agent brings is knowing what the issuer needs to see. A challenge or an update succeeds on its evidence, which in most cases means a current CRO company printout, the certificate of incorporation on change of name issued by the CRO or ownership records that support a Level 2 relationship. Send the right document the first time and the correction usually goes through. Send the wrong one and it comes back unresolved.
The other half of the job is the lifecycle. An LEI has to be renewed every year, and one that misses its renewal date is marked as lapsed. The status shows that its reference data has not been re-validated on schedule, which counterparties and regulators may reject regardless of whether the underlying details are still correct. For derivatives reporting under EMIR this is set out explicitly. Since 29 April 2024, Commission Implementing Regulation (EU) 2022/1860 has required the reporting counterparty and the entity responsible for reporting to ensure that their LEI is duly renewed when they report the conclusion or modification of a derivative contract. You can read more about EMIR in our article on what MiFID II and EMIR are and why they matter. Renewing a lapsed LEI is also how its data is brought up to date. During renewal, the entity submits any changes to its reference data, the issuer validates them and the LEI returns to issued status. Our guide to renewing your LEI number covers the timing. If your LEI is managed elsewhere and you are not getting the data support you need, transferring an LEI code to LEI Ireland explains how to move it.
What You Should Do Now
First, look at your own record. Open the Global LEI Index search, enter your LEI or your legal name and read every field rather than glancing at the name. Pay particular attention to the legal name in full including its legal form, the registered office address, the entity status, the next renewal date and any parent relationship or reported exception.
Second, write down what does not match, and find the document that proves it. A discrepancy without evidence is a query. A discrepancy with a current CRO company printout attached is something an issuing organisation can act on.
Third, decide on the route before you act. If we manage your LEI, the shortest path is to send what you found to the LEI Ireland team. We confirm whether the field is actually wrong or is only displayed in a way that looks wrong, prepare the evidence and submit a data update or a challenge. From your side that is one email, plus a signature if we do not already hold your power of attorney, and for an LEI that has not lapsed the correction itself is free of charge. If the problem sits in a counterparty’s record, a challenge through the Data Challenge Facility is the direct route.
Finally, use the two features once a challenge closes. Rate the resolution while the 28-day window is open, and if the outcome left the original issue standing, resubmit with the additional context or evidence rather than letting it lapse. Reviewing your record after corporate events such as a merger, a change of name or an ownership transition catches most problems before a counterparty finds them for you.
If you need to register a new LEI, renew an existing one or correct the data in a record you already hold, you can do this online through LEI Ireland at https://lei-ireland.ie, an official LEI Registration Agent for Irish businesses, working with our accredited LEI issuing organisation EQS Group.