Regulatory Framework: the ZISIF Act and European Legislation
The activities of alternative investment funds under §15 are governed by Act No. 240/2013 Coll. on Investment Companies and Investment Funds (Zákon o investičních společnostech a investičních fondech, ZISIF). This Act defines the regime of “asset management comparable to fund management” (správa majetku srovnatelná s obhospodařováním) as a simplified form of collective investment.
At the European level, the regulation of alternative investment funds is defined by the AIFMD (2011/61/EU) — the Alternative Investment Fund Managers Directive. The §15 ZISIF regime represents the implementation of the so-called “sub-threshold” AIFMD regime, intended for managers with assets under management below the established thresholds.
ČNB does not exercise prudential supervision over managers under §15 ZISIF. The fund manager must register in the ČNB public register pursuant to §596(e) of Act 240/2013 Coll. Registration is solely of a notification nature: ČNB does not verify the accuracy of the information provided and does not assess the manager’s compliance with any qualification requirements. However, ČNB monitors whether the volume of assets under management is approaching the threshold requiring a full licence.
Advantages of Registering an Alternative Investment Fund in the Czech Republic
Relative simplicity of registration
The notification procedure instead of full licensing significantly reduces the time and cost of market entry.
No minimum share capital requirements
The initial capital of the fund can be as little as CZK 1, making the structure accessible to a wide range of initiators.
Flexibility of investment strategy
Unlike regulated investment funds, the manager under §15 ZISIF independently determines operational features and investment strategy without the need for approval from the regulator.
Minimal administrative burden
The fund is required to submit to ČNB only one annual report on the volume of assets under management, which significantly reduces operational costs.
Attractive jurisdiction
The Czech Republic, as an EU member since 2004, provides a reliable legal system, developed banking infrastructure, and relatively low operational costs compared to Western Europe.
Requirements for Obtaining Registration
Since 1 January 2021, managers under §15 ZISIF have been mandatory subjects of Act No. 253/2008 Coll. on the Prevention of Money Laundering and Terrorist Financing (AML Act). The manager is required to develop a System of Internal Principles in the area of AML/CFT and send it to the Financial Analytical Office of the Czech Republic (Finanční analytický úřad, FAÚ). The deadline is 60 days from the moment the manager became an obliged person. Non-compliance with this requirement carries a fine of up to CZK 1,000,000. AML/CFT supervision is exercised by FAÚ alone, not by ČNB; changes to the System of Internal Principles are notified to FAÚ within 30 days of their adoption.
COREDO Service Costs
Registering an alternative investment fund under §15 ZISIF in the Czech Republic with COREDO costs from EUR 8,500 + VAT — this covers entering the manager in the ČNB register, with the ČNB administrative fee inside the price. We register the company for the fund for EUR 1,250 + VAT — the same price as a standard company registration in the Czech Republic.
Notary and court fees for entering the company in the commercial register are paid separately, on top of COREDO’s price.
The final cost may vary depending on the complexity of the specific project, the number of founders and investors, and the specifics of the investment strategy. COREDO provides an individual cost estimate following a preliminary consultation and analysis of the client’s business model.
Additionally, COREDO offers a ZISIF §15 fund AML servicing package starting from CZK 23,900 per month (annual subscription — CZK 75,600 per year), which includes maintaining AML/CFT documentation up to date and ongoing support.
Payment Terms
The payment schedule is set in the service agreement.
All settlements are made in euros (EUR), and VAT is charged in accordance with the legislation of the Czech Republic.
List of Documents for Registration
For registration of a legal entity in the Czech Republic (Stage 1), the following are required: a scan of the passport of the director/founder, proof of address of the director/founder (no older than 3 months), signed power of attorney and affidavit from the director/founder, criminal record certificate of the director (no older than 3 months), description of the fund’s activities indicating the investment strategy.
For submitting the application for registration in the ČNB register (Stage 2), the following are required: completed application form in the prescribed format, corporate documents of the established company, documents of the director/founder of the fund, a document confirming the business authorisation (živnostenský list or another authorisation), a description of the manager’s activities, an offer for each managed structure — a statute, articles of association, a founding document or a model agreement with the investment strategy. The application is filed electronically: via the ČNB data box or with a qualified electronic signature.
An extended document with a detailed description of the fund’s activities may be attached to the application, which will serve as the basis for further relations with investors.
Alternative Investment Fund Registration Procedure
Preliminary Consultation and Analysis
COREDO specialists analyse the client’s business model, determine the optimal fund structure, and develop a project implementation plan. At this stage, key parameters are agreed upon: legal form (s.r.o. or a.s.), investment strategy, investor circle, and management structure. Duration: 1–2 weeks.
Legal Entity Registration
COREDO registers the company in the Czech Republic in the chosen legal form. This stage includes preparation of incorporation documents, registration in the commercial register, and obtaining the necessary registration numbers. Duration: 2 weeks from the receipt of all required documents.
Fund Documentation Preparation
Preparation of the full document package for fund registration, including the investment offer — the contractual document for investors in the form of a statute or model agreement, the description of the manager’s activities and the description of the investment strategy under Art. 5(2) AIFMR. Duration: 2–3 weeks.
Application Submission and ČNB Registration
Submission of the notification and the full document package to the Czech National Bank for inclusion in the public register of managers under §15 ZISIF. ČNB makes the entry in the register within 5 working days, without reviewing the content of the documents. Duration: 5 working days from the moment ČNB receives the complete application.
Registration in the SDAT Information System and Operational Launch
Following registration in the ČNB register, the manager is required to apply for registration in the ČNB information system (SDAT) and obtain an electronic certificate for signing reports. COREDO sets up reporting in SDAT and helps file the reports. We develop the internal AML/CFT policies and file the notification with FAÚ.
The overall project timeline is up to 2 months on average and depends on how quickly the documents are prepared.
Our Experts
The registration of alternative investment funds under §15 ZISIF in the Czech Republic is overseen by COREDO’s senior management and leading specialists.
Frequently Asked Questions
COREDO specialists help clients register alternative investment funds in the Czech Republic. We offer full project support — from the initial consultation to successful registration in the ČNB register and launch of the fund’s operations.
