LEI for Funds – ICAV, UCITS, AIF & Sub-Fund Requirements
Quick Answer
Under AIFMD, UCITS, and MiFID II, most investment funds need their own LEI—including each sub-fund within an umbrella structure. ICAVs, SICAVs, unit trusts, and limited partnerships each require a separate LEI. Use the Fund Relationships tool to explore fund hierarchies. LEI Search is provided by LEI Worldwide, an official GLEIF Registration Agent.
Which Funds Need an LEI?
| Fund Type | LEI Required? | Key Regulation |
|---|---|---|
| UCITS | Yes | MiFID II / MiFIR |
| AIF | Yes | AIFMD / EMIR |
| ICAV | Yes | Central Bank of Ireland |
| SICAV | Yes | Luxembourg / France regulations |
| Sub-fund | Yes (separate from umbrella) | GLEIF guidelines |
| ETF | Yes | MiFID II / exchange rules |
Umbrella and Sub-Fund Structures
In an umbrella fund structure, the umbrella entity and each sub-fund are distinct legal entities for LEI purposes. GLEIF's Level 2 relationship data captures the parent-child relationship between the umbrella and its sub-funds. The Fund Relationships tool visualises these hierarchies, showing fund managers, administrators, and custodians.
Fund Manager vs Fund LEI
The fund management company (ManCo) has its own LEI, separate from the funds it manages. In GLEIF data, the ManCo is recorded as the "direct parent" of each fund. This distinction is important for regulatory reporting—trade reports must reference the fund's LEI, not the manager's.
ISIN-to-LEI Mapping for Funds
Each share class of a fund has a unique ISIN, while the fund entity has a single LEI. Use the ISIN to LEI Mapper to convert ISINs to their corresponding fund LEIs—essential for compliance teams reconciling holdings data.
Frequently Asked Questions
Does each sub-fund need its own LEI?
Yes. Under GLEIF guidelines, each sub-fund within an umbrella structure is a distinct legal entity and requires its own LEI, separate from the umbrella fund's LEI.
What is the difference between a fund LEI and a fund manager LEI?
The fund management company (ManCo) has its own LEI. Each fund it manages also has a separate LEI. Trade reports must reference the fund's LEI, not the manager's.
Do ETFs need an LEI?
Yes. Exchange-traded funds listed on regulated exchanges are required to have an LEI for transaction reporting under MiFID II, EMIR, and other regulations.
How do I find a fund's LEI?
Search for the fund's legal name on LEI Search (leisearch.com). You can also use the Fund Relationships tool to explore umbrella and sub-fund hierarchies.
How are fund relationships captured in LEI data?
GLEIF Level 2 data captures parent-child relationships between umbrella funds and sub-funds, as well as links to fund managers and administrators.
Can I map ISINs to fund LEIs?
Yes. Each share class has a unique ISIN while the fund has a single LEI. Use the ISIN to LEI Mapper on leisearch.com to convert ISINs to their corresponding fund LEIs.