Pretty much! (Securities like this are also something of a headache for compliance people since _technically_ they can be caught by current regulations not written with them in mind. Good luck getting an LEI for this bond’s issuer. (An actual concern I’ve seen raised by people responsible for such things)

I checked it, and the issuer of this bond (Hoogheemraadschap De Stichtse Rijnlanden) indeed does not seem to have a LEI!

For those like me that didn't know

"The Legal Entity Identifier (LEI) is a reference code — like a bar code — used across markets and jurisdictions to uniquely identify a legally distinct entity that engages in a financial transaction."