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Challenge Policy

Effective date: 29-Sep-2026

1 Purpose and status

This Challenge Policy is the communication policy of LEI International Private Limited, trading as TNV-LEI (LOU prefix 9269), for challenges to LEI data. It explains who may challenge LEI data managed by TNV-LEI, how to submit a challenge, how TNV-LEI handles it and the time limits that apply.

It gives the procedure for Section 8.2 of the General Terms and Conditions for LEI Services published at www.tnvlei.com/terms, and follows the GLEIF Service Level Agreement (Appendix 06 to the GLEIF Master Agreement) and GLEIF's "Challenge LEI and vLEI Data" facility on LEI Search. For customers of TNV-LEI, if this Policy and the General Terms and Conditions differ, the General Terms and Conditions prevail. Nothing in either reduces the rights of any person under applicable law.

In this Policy, LOU business day means Monday to Friday, excluding public holidays observed by TNV-LEI in Uttar Pradesh, India. Periods stated in days are calendar days.

2 Who may submit a challenge

Any person or organization may challenge the accuracy or completeness of LEI data managed by TNV-LEI. The challenger does not need to be the Legal Entity, a customer of TNV-LEI or an account holder. This includes the Legal Entity itself, other data users, authorities, other LEI issuers and GLEIF.

The challenger must give a working email address so that TNV-LEI can acknowledge the challenge, ask follow-up questions and report the outcome.

3 What may be challenged

A challenge may concern any of the following for an LEI managed by TNV-LEI:

  • the reference data of the LEI record, for example legal name, other names, legal form, legal and headquarters addresses, registration authority and registration number, and entity status;
  • the relationship data of the LEI record, for example the direct and ultimate accounting consolidating parents or the reporting exception given for them;
  • the registration data of the LEI record, for example its registration status;
  • legal entity events recorded on the LEI record;
  • a suspected duplicate, where two LEIs appear to identify the same Legal Entity; and
  • the eligibility of the entity to hold an LEI.

Challenges raised through GLEIF's LEI Search follow GLEIF's own rules on which parts of a record can be challenged. Mappings to other identifiers such as BIC or ISIN, vLEI credentials and other data added by GLEIF rather than by TNV-LEI are not TNV-LEI's data and cannot be challenged under this Policy by any route.

4 How to submit a challenge

A challenge may be submitted in any of these ways:

  • by email to challenge@tnvlei.com;
  • through the challenge facility on the TNV-LEI dashboard at app.tnvlei.com, for signed-in users; or
  • through GLEIF's LEI Search at search.gleif.org, using the option to challenge the LEI record. GLEIF forwards the challenge to TNV-LEI.

Please state the LEI, the data that is disputed, the value you believe is correct if you know it, or otherwise an explanation of the suspected error, and your contact email. You do not need to know the exact replacement value to raise a challenge. Attach or link the evidence, for example an extract from the official business register, a filed document or an audited financial statement for parent information. Evidence in a language other than English should be accompanied by a translation; TNV-LEI may ask for a certified translation where the meaning is unclear.

5 Acknowledgement and time limits

TNV-LEI acknowledges a challenge sent directly to it by email or through the dashboard within one LOU business day. Challenges raised through GLEIF's facility are acknowledged by GLEIF's system when they are submitted.

TNV-LEI investigates each individual challenge and gives a substantive response, including any correction, within the GLEIF service levels: a processing target of 15 calendar days and a maximum processing time of 25 calendar days. These periods run from the day the challenge is submitted to TNV-LEI, which for a challenge raised through GLEIF's LEI Search is the day GLEIF forwards it. A request for clarification or further evidence does not stop the clock; if the information is not received by the date given, TNV-LEI decides on the evidence it holds. An acknowledgement alone is not a substantive response. Bulk challenges, as GLEIF defines them, follow the arrangements GLEIF sets for them.

6 How TNV-LEI handles a challenge

6.1 Assessment and verification

TNV-LEI checks that the challenge is understandable and complete and verifies the challenged data against the authoritative sources that apply to the entity's jurisdiction. It may ask the challenger for clarification or further evidence.

6.2 Informing the Legal Entity

TNV-LEI informs the Legal Entity of the challenge, of the result of its verification and of any steps the Legal Entity needs to take. The Legal Entity is asked to reply within seven calendar days. TNV-LEI does not give the Legal Entity the challenger's name or contact details unless the challenger agrees.

TNV-LEI then decides as follows:

  • If the authoritative source supports the challenge and the Legal Entity agrees, or does not reply within the seven days, TNV-LEI corrects the record under Section 5.2 of the General Terms and Conditions and applicable GLEIF requirements, and notifies the Legal Entity of the correction and its basis. A reply from the Legal Entity is not a precondition for a correction that the authoritative source confirms.
  • If the authoritative source does not support the challenge, the challenge is not upheld.
  • If the Legal Entity's reply conflicts with the authoritative source, TNV-LEI asks the Legal Entity to have the source registry corrected first. TNV-LEI still decides the challenge within the 25-day maximum on the evidence it then holds and tells both parties what it decided and why. Where the record is updated on the Legal Entity's information alone, the validation level recorded in the LEI record shows that the data is not fully corroborated.

Obvious errors, such as a misspelt city name or postal code, or a placeholder value in a data field, may be corrected without waiting for the Legal Entity's reply, and the Legal Entity is notified of the correction.

6.3 Decision and publication

If the challenge is upheld, TNV-LEI updates the LEI record and submits it to GLEIF in its next regular upload. If the challenge is not upheld, the record is not changed and TNV-LEI explains why.

TNV-LEI tells the challenger and the Legal Entity the outcome and, so far as confidentiality allows, its reasons. For challenges raised through GLEIF's facility, TNV-LEI records the result and closes the challenge in the GLEIF Challenge Management Facility, which notifies the challenger.

Evidence and personal data supplied with a challenge are kept confidential. They are used to resolve the challenge and are kept as records under Section 8, which TNV-LEI must make available to GLEIF and authorized auditors. They are not published. Only the resulting change to the LEI record becomes public.

6.4 Escalation

If TNV-LEI cannot resolve a challenge on the evidence available, or the Legal Entity or the challenger disputes the outcome, TNV-LEI explains its position to both and refers the matter through the applicable GLEIF process. A referral does not by itself extend the 25-day maximum.

7 If you disagree with the outcome

A challenger who disagrees with the outcome may submit a new challenge with further evidence. For a challenge raised through GLEIF's facility, GLEIF's re-submission option is available within 28 days after the challenge is closed, and GLEIF also invites feedback on the resolution within the same period. A re-submitted challenge is handled as a new challenge linked to the earlier one.

A Legal Entity that disagrees with an outcome may request an update with new evidence under Section 8.1 of the General Terms and Conditions, or complain to support@tnvlei.com.

Complaints about how TNV-LEI handled a challenge, as opposed to the data itself, may be sent to support@tnvlei.com. TNV-LEI replies within 30 calendar days.

8 Records

TNV-LEI keeps a record of each challenge, including the date received, the LEI, the data challenged, the evidence, communications, the decision, any change made and the closure date. Each challenge record, together with its supporting evidence and correspondence, is an LOU-Record and is kept for the period in Section 11.5 of the General Terms and Conditions, applied to that record: at least ten years after the most recent update to the challenge record itself, throughout the term of TNV-LEI's Master Agreement with GLEIF and for five years after it ends, whichever is longer. This applies whether or not the challenge led to a change in the published LEI record.

9 Contact

Challenges: challenge@tnvlei.com
Complaints about challenge handling: support@tnvlei.com
Postal address: LEI International Private Limited, TNV House, B-1/19/69, Sector-K, Aliganj, Lucknow 226024, Uttar Pradesh, India

10 Changes to this Policy

TNV-LEI reviews this Policy at least once a year and when GLEIF changes its challenge requirements. Changes are published on this page with a new version number and effective date.

Version 2.00 | Publication date: 29-Sep-2026