The United States has taken a decisive step toward standardizing how its financial regulators identify legal entities. On June 25, 2026, nine federal financial agencies, including the Securities and Exchange Commission (SEC), the Federal Reserve Board, and the Commodity Futures Trading Commission (CFTC), published the final joint rule under the Financial Data Transparency Act (FDTA) in the Federal Register. The rule establishes the Legal Entity Identifier (LEI), defined by ISO 17442, as the common legal entity identifier within the FDTA joint data standards. Its application to specific filings and reporting entities will depend on subsequent agency action.
The final joint rule takes effect on October 1, 2026. Here is what it decides, what it leaves for later, and what it means in practice for organizations that report to U.S. financial regulators.
What this means today: The joint rule does not require companies to obtain an LEI or change their current filings. Organizations that report to the SEC, the Federal Reserve Board, the FDIC, the OCC, or other covered agencies should follow the upcoming agency-specific rules and, if they already hold an LEI, make sure it remains active and up to date. Businesses that do not report to covered financial regulators are unlikely to be directly affected by the next phase of implementation.
What Is the FDTA?
The Financial Data Transparency Act was signed into law on December 23, 2022. It amended the Financial Stability Act of 2010 by adding Section 124, which requires the covered agencies to jointly establish data standards for certain collections of information reported by financial entities under the agencies’ jurisdiction, as well as data collected from the agencies on behalf of the Financial Stability Oversight Council.
One of the central problems the FDTA set out to solve is fragmentation. U.S. federal agencies have historically operated across more than 50 distinct, incompatible entity identification systems. The same company could be recorded under different identifiers in different regulatory databases, which made it difficult for regulators to aggregate data, compare filings, or build a complete picture of risk across the financial system. The 2008 financial crisis had already demonstrated the consequences of fragmented entity identification. When Lehman Brothers collapsed, regulators and market participants struggled to assess aggregate exposures across the financial system because no common global identifier linked the relevant records.
What the Final Joint Rule Establishes
The centerpiece of the final joint rule is the LEI. The agencies concluded that the LEI meets the FDTA’s requirements for a legal entity identifier: it is common, nonproprietary, and available under an open license. The LEI is a 20-character alphanumeric code based on the ISO 17442 standard that uniquely identifies a legal entity, and its reference data is freely available to anyone through the Global LEI Index, maintained by the Global Legal Entity Identifier Foundation (GLEIF).
The rule also establishes several other joint standards, including ISO 8601 for dates, ISO 4914 (UPI) for the identification of swaps and security-based swaps, and ISO 10962 (CFI) for the classification of financial instruments other than swaps and security-based swaps. Notably, the agencies decided not to adopt the Financial Instrument Global Identifier (FIGI) that had been included in the 2024 proposal, after commenters expressed divided views on its utility and costs.
Taken together, the joint standards lay the foundation for reducing the fragmentation that has long characterized federal financial data. They do not erase the existing systems overnight, but they give every covered agency a common reference point to build on.
What the Rule Does Not Do (Yet)
This part matters just as much as what the rule establishes. The final joint rule applies directly to the agencies, not to private companies or other reporting entities. It does not itself require any company to obtain an LEI, and it does not change current reporting practices. Existing reporting requirements do not automatically change on the effective date. The rule sets the standards; it does not yet apply them to specific filings.
In other words, if your organization does not hold an LEI today, nothing in the joint rule creates an immediate obligation to get one. The obligations, where they arise, will come in the next phase.
The Two-Year Implementation Window
The joint rule takes effect on October 1, 2026, but the implementation timeline is governed separately by the FDTA. Seven of the nine participating agencies, the OCC, the Federal Reserve Board, the FDIC, the NCUA, the CFPB, the FHFA, and the SEC, are designated as implementing agencies under the FDTA. The data standards adopted through their agency-specific rulemakings must take effect no later than two years after the final joint rule is promulgated. The CFTC and the Treasury participated in the joint rule but are not subject to the same FDTA agency-specific rulemaking mandate. They may incorporate the joint standards through other agency actions or under separate authority.
Those agency rulemakings are where the practical substance of the FDTA will be decided: which forms and collections of information the standards apply to, which reporting entities are affected, and whether and how the LEI is required in particular filings. The agencies also retain meaningful flexibility. They may tailor the joint standards during implementation, scale requirements to minimize disruption, account for the burden on smaller entities, and in specific cases use a different identifier instead of, or alongside, the LEI if the agency finds the joint standard infeasible or another approach less disruptive. So while the direction of travel is clear, the exact scope of future LEI requirements will emerge agency by agency during the agency-specific implementation period.
Who Should Pay Attention
The organizations that should pay closest attention are those that already report to the covered agencies. This may include banks and credit unions, securities and derivatives market participants, investment advisers, mutual funds, and other regulated financial entities that submit financial data to the SEC, the CFTC, the Federal Reserve Board, the FDIC, the OCC, and their peers.
Organizations that report to these agencies should monitor whether and how the FDTA standards are incorporated into the filings they submit. The final scope will depend on the agency, the information collection, and the outcome of each implementation process. Many participants in the derivatives markets already hold LEIs, since U.S. regulators have long used the identifier in that context. For others, the coming agency rulemakings will determine what changes.
Companies that do not report to covered financial regulators are less likely to be directly affected for now, although broader adoption of the LEI in the U.S. may increase its usefulness in areas such as counterparty verification, onboarding, and cross-border business.
Preparing Ahead of Agency Rules
There is a practical case for preparing ahead. For an organization that is likely to fall within the future scope, obtaining an LEI or renewing a lapsed one in advance may reduce the administrative work required later. It does not replace the need to monitor applicable agency rules, but it can mean one less item to address if a future agency rule or other action requires an LEI. An active LEI can also support existing use cases such as certain derivatives reporting requirements, counterparty identification, due diligence, and cross-border onboarding, depending on the applicable rules and transaction.
You can register or renew your LEI through americanlei.com.
Frequently Asked Questions
Does the FDTA require my company to obtain an LEI?
Not under the final joint rule. The rule establishes the LEI as the common legal entity identifier within the joint standards, but it does not itself impose reporting obligations on companies. A future agency-specific rule may require the LEI for particular filings or reporting entities.
When does the FDTA final rule take effect?
The joint rule takes effect on October 1, 2026. Data standards adopted by the implementing agencies through their agency-specific rulemakings must take effect no later than two years after the final joint rule is promulgated.
Which agencies are covered by the FDTA?
Nine agencies participated in the final joint rule: the OCC, the Federal Reserve Board, the FDIC, the NCUA, the CFPB, the FHFA, the CFTC, the SEC, and the Department of the Treasury. Seven of them, all except the CFTC and the Treasury, are designated as implementing agencies required to adopt agency-specific standards for certain collections of information.
What is ISO 17442?
ISO 17442 is the international standard that defines the Legal Entity Identifier: a 20-character alphanumeric code that uniquely identifies a legal entity participating in financial transactions. The Global LEI System is overseen by the Regulatory Oversight Committee. GLEIF is responsible for its operational integrity and for maintaining the Global LEI Index, while accredited LEI issuers issue and maintain individual LEI records.
The Bottom Line
The FDTA final joint rule is a foundation, not a finish line. It establishes the LEI as the common legal entity identifier for the FDTA standards, and the seven implementing agencies must now reflect those standards in their own rules where feasible. Organizations that are likely to fall within the future scope should consider obtaining an LEI, or ensuring that an existing LEI remains active and up to date, before the agency-specific requirements take effect.
Register your LEI or renew an existing LEI for the U.S. market.