When planning investments under the PFR Ventures program, many companies wonder whether an Alternative Investment Company (ASI – Alternatywna Spółka Inwestycyjna) or an External Manager of ASI (ZASI) can be recognized as a Private Investor. This article explores that question by reviewing the definition of a Private Investor and the conditions that must be met to qualify for this status.
Definition of a Private Investor in PFR Ventures
According to the terminology used in the PFR Ventures program, a Private Investor is an entity that meets several key criteria. Most importantly, it must contribute its own capital to a VC Fund, and that capital must not originate from public sources. This means that funds invested by an ASI or ZASI company must not be financed with public money as defined by relevant legislation.
Conditions to Be Met
To be recognized as a Private Investor, an ASI or ZASI company must meet the following conditions:
- Provide its own capital contribution to the VC Fund, not derived from public sources.
- Be independent from the Fund Manager and the Portfolio Company.
- Not hold shares or equity in the Portfolio Company at the time of the initial investment.
Full Risk Exposure
A Private Investor under the PFR Ventures program assumes full risk associated with the investment. This means that an ASI or ZASI company must be aware of and prepared for potential losses related to the investment.
Legal Basis for Participation Rights
Ultimately, to be recognized as a Private Investor, an ASI or ZASI company must also meet additional conditions outlined in the Investment Funds Act and the regulations governing the PFR Ventures program.
Frequently Asked Questions (FAQs)
What are the main criteria for being a Private Investor? The key criteria include contributing private capital, maintaining independence from the fund manager and portfolio company, assuming full investment risk, and meeting specific legal conditions for participation in a VC Fund.
Are there other restrictions for Private Investors? Yes. For example, entities engaged in financial services may not be treated as private investors under the program.
Can an ASI or ZASI company be a Private Investor in the PFR Ventures STARTER program? Yes, provided it meets the required criteria, including the condition that its capital does not come from public sources.
How can an ASI or ZASI company verify its eligibility as a Private Investor under the PFR Ventures STARTER program? It is essential to review the definition of a Private Investor and the specific conditions of the STARTER program, and to consult with financial and legal experts specializing in venture capital.
Are there any exceptions for ASI or ZASI companies under the PFR Ventures STARTER program? No. The criteria for Private Investors apply equally to all entities, regardless of their type.
Where can I find more information about Private Investor status in the PFR Ventures STARTER program? Detailed information is available on the official website of PFR Ventures and in the documents governing the STARTER program: https://pfrventures.pl/dla-funduszy/PFR-Starter
Summary
In conclusion, an ASI or ZASI company can qualify as a Private Investor under the PFR Ventures program, provided it meets all the criteria defined for this type of investor. Entrepreneurs seeking alternative sources of financing should carefully review these requirements and consult with professionals to ensure their company complies with the program’s rules.
Need guidance on ASI eligibility or venture capital participation? Contact us for expert support!

