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. It is important to note that, unlike full AIFMD managers, funds under §15 ZISIF do not have the right to passporting — meaning they cannot offer their services in other EEA countries based on Czech registration.
ČNB does not exercise prudential supervision over managers under §15 ZISIF. 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
Registration of an alternative investment fund under §15 ZISIF in the Czech Republic offers a number of significant advantages.
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.
Wide range of permissible assets
the fund may invest in virtually any asset class — from traditional financial instruments to real estate and crypto-assets.
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
To register an alternative investment fund under §15 ZISIF, the following requirements must be met.
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, within 60 days of commencing operations, to develop and submit to ČNB a System of Internal Principles in the area of AML/CFT. Non-compliance with this requirement carries a fine of up to CZK 1,000,000.
Mandatory AML/CFT procedures include: identification and screening of investors, verification of the source of funds and beneficial ownership, maintenance of AML records and documentation, and implementation of internal policies for the prevention of money laundering and terrorist financing.
COREDO Service Costs
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.
Payment Terms
Payment for COREDO services for the registration of an alternative investment fund is made in stages. The first payment of 40% of the total cost is made upon signing the agreement and commencement of work. The second payment of 40% is made at the stage of document submission to ČNB. The final payment of 20% is made upon completion of the fund’s registration in the ČNB register.
This staged payment system ensures transparency and links payments to specific results at each stage of the project. 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
The registration process for an alternative investment fund under §15 ZISIF consists of two main stages, each requiring a specific set of documents.
For registration of a legal entity in the Czech Republic (Stage 1), the following are required: scans of two identity documents of the director/founder — passport and ID card or driving licence (both sides), 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, offer in the form of an investment agreement, articles of association, or a general description of the investment strategy. The offer must contain: a brief description of the main asset categories for investment (limited to two to three lines of A4 format), information on the industry, geographic or other market segments, or specific asset classes of the target investment strategy, information on the borrowing or leverage policy indicating the types and purposes of derivatives used.
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
The registration process for an alternative investment fund under §15 ZISIF includes several sequential stages.
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: approximately 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, description of the investment strategy, and internal policies. At this stage, the AML/CFT System of Internal Principles is also developed. 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 processes the notification within several business days. Duration: up to 2 weeks.
Registration in the SDAT Information System and 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 accompanies the client at this final stage. Duration: 1–2 weeks.
The overall project timeline is 1.5 to 2.5 months, depending on the speed of information exchange between the parties and the regulator’s workload.
Our Experts
The registration of alternative investment funds under §15 ZISIF in the Czech Republic is overseen by leading specialists of COREDO’s legal team.
Frequently Asked Questions
COREDO specialists have been helping clients register alternative investment funds in the Czech Republic since 2016. We offer full project support — from the initial consultation to successful registration in the ČNB register and launch of the fund’s operations.