In advance of the implementation date for MiFID II on 3 January 2018, ESMA has issued a public statement that provides a form of 6 month transitional period for certain trading venues and certain legal persons, to support the introduction of Legal Entity Identifier (LEI) requirements.  This includes provision that trading venues whose non-EEA issuer clients do not yet have LEIs will be able to use their own LEIs instead during this period.

The FCA responded to the ESMA statement by confirming that they would be amending and applying their rules accordingly, but encouraging all firms to ensure they are using LEIs at the earliest opportunity.