In April 2024, the Bank of England released a revised policy statement on the compulsory adoption of ISO 20022 in the Clearing House Automated Payment System (CHAPS) for enhanced data. This update outlines the requirements that will take effect in 2025 and 2026, emphasising the BoE’s collaboration with the payments industry to harness the benefits of enhanced data for greater efficiency, better payment prioritisation, and the prevention of financial crime.
A key element of this mandate is the requirement for certain CHAPS payments to include Legal Entity Identifiers (LEIs). This has been deferred from November 2024 to 1 May 2025.
From 1 May 2025, the Bank will mandate the use of LEIs for all payments between financial institutions, as set out since our 2020 policy statement. This requirement applies to payments made via a channel controlled by the DP until our proposed expansion to all channels from November 2027.
The Bank continues to encourage the inclusion of LEIs for all CHAPS payments where possible prior to this date.
It remains the Bank’s vision to widen the LEI requirement to all CHAPS payments over time.
Bank of England
Key Points on LEI Requirement
- Introduction of LEIs: The LEI is a unique global identifier for corporate entities involved in financial transactions. Its consistent use is expected to support better financial crime detection, improved resolution planning, sanctions screening, and customer due diligence. This aligns with broader goals of enhancing financial stability and transparency.
- Scope of Mandate: From 1 May 2025, the use of LEIs will be mandated for CHAPS payments between financial institutions. This mandate aims to streamline and secure high-value transactions within the financial sector.
Benefits of LEIs:
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- Enhanced Transparency: LEIs provide a standardised way to identify legal entities involved in financial transactions, enhancing transparency and risk management.
- Global Consistency: A significant proportion of CHAPS payments are cross-border and therefore require global harmonisation of messaging standards. The adoption of LEIs aligns with global regulatory initiatives, ensuring consistency and facilitating cross-border payments.
- Implementation: Participants must ensure their systems can incorporate LEIs into payment messages, requiring updates to data management and processing workflows.
- Risk Reduction: Improved entity identification helps in reducing financial crime and enhancing the monitoring of financial transactions.
- Operational Efficiency: LEIs streamline processes by providing a unique identifier for entities, reducing errors and ambiguities in payment processing.
The adoption of LEIs is anticipated to make payment processing faster and cheaper, ultimately benefiting end-consumers. LEIs help in providing standardised and precise identification of parties involved in transactions, which enhances the overall efficiency and reliability of the financial system.
We encourage DPs (CHAPS Direct Participants) to enrich their internal customer databases with LEIs, both to help meet our CHAPS requirements and for the wider benefits for financial transparency.
Bank of England
Implementation Timeline and Updates
- June 2023: The CHAPS system successfully migrated to the ISO 20022 messaging standard, setting the stage for enhanced data capabilities.
- May 2025: LEIs will become mandatory for payments between financial institutions. Additionally, purpose codes for property payments and transactions between financial institutions will also be required.
- November 2025: Further enhancements, including structured addresses and remittance information, will be mandated to ensure comprehensive adoption of the ISO 20022 standard across various transaction types.
The Bank of England is actively engaging with industry stakeholders through the Enhanced Data Working Group to support a smooth transition and ensure that all parties are prepared for these upcoming changes. This collaborative approach aims to maximise the benefits of the richer data standard provided by ISO 20022, such as improved fraud prevention, better payment prioritisation, and enhanced customer insights.
Addressing LEI requirements through the Validation Agent programme
CHAPS Direct Participants (DPs), such as banking institutions, should now be preparing to support high volumes of Legal Entity Identifiers (LEIs). Collaborating with an LEI Issuer that can manage large-scale issuance and assist DPs in handling the full lifecycle of LEIs on behalf of their clients is essential.
The Bank encourages all DPs (CHAPS Direct Participants) to consider the Global Legal Entity Identifier Foundation’s (GLEIF) Validation Agent model and – more generally – checking whether customers already possess LEI(s) during on-boarding. This reflects the growing importance of the LEI in global developments in financial transparency.
Bank of England
Ubisecure RapidLEI has onboarded and supported several high-profile banking institutions including Citi, BNP Paribas, Sparkasse Bank, and the Commonwealth Bank of Australia into the Validation Agent (VA) programme. As a VA, banks can streamline and automate the LEI issuance process for their clients, significantly reducing both time and costs.
For more information on becoming a Validation Agent ready for the Enhanced Data please visit https://rapidlei.com/gleif-validation-agents/.
Additional Resources:
CHAPS LEI eBook
Ubisecure RapidLEI has published a free eBook with detailed insights and guidance on the adoption of ISO 20022 and LEIs in the CHAPS system. This eBook is designed to help financial institutions and other stakeholders understand and implement the necessary changes effectively.
Download the eBook:
Decoding LEI Requirements for the CHAPS ISO 20222 Enhanced Data Policy.
Bank of England Updates
For more details and to stay updated on any further changes, stakeholders are encouraged to regularly consult the Bank of England’s communications and updates on the implementation of ISO 20022 in CHAPS.Sources:
- Bank of England Policy Statement on ISO 20022 Enhanced Data in CHAPS
(Bank of England)
About The Author: Steve Waite
Steve is the Chief Marketing Officer for Ubisecure and RapidLEI.
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