For venture capital entities · Section 15 ZISIF
Audit under Section 15 ZISIF – auditor's report on compliance with the investor limit
Do you raise funds from more than 20 investors? Then every year by 30 June you must submit an auditor's report to the Czech National Bank confirming that no more than 20 of them invested less than EUR 125,000. We will carry out the verification well in advance, at a price agreed up front and with the experience of an audit firm operating since 1993.
- Since 1993
- Licensed by the Czech Chamber of Auditors
- Czech and English
Auditor's report under Section 15(6) ZISIF
- No more than 20 investors below EUR 125,000
- Verified for the 2026 calendar year
- Ready for submission via SDAT
Does the auditor's report obligation apply to you?
On 1 July 2026, the transitional period of the ZISIF amendment (Act No. 163/2024 Coll.) ended. The investor limit and the auditor's report obligation now apply to all venture capital entities – including those entered in the CNB list before July 2024.
You are a venture capital entity
A legal entity seated in the Czech Republic that, without a CNB licence, manages assets collected from investors for collective investment and is entered in the CNB list under Section 15 ZISIF.
You have more than 20 investors
The obligation arises as soon as you raise funds from more than 20 investors in total – including those who invested EUR 125,000 or more.
The deadline is always 30 June
You submit the report to the CNB electronically via the SDAT system by the end of the sixth month after the end of the calendar year. For 2026, this means 30 June 2027 at the latest.
Why it matters: In the event of a serious or repeated breach of this obligation, the CNB may remove the venture capital entity from the list. Re-registration is only possible after 10 years (Section 15a ZISIF).
What exactly we verify
The law allows you to accept funds from no more than 20 investors who invested less than EUR 125,000. We will verify that you complied with this limit during the calendar year and issue the auditor's report for you to submit to the CNB.
We focus on
- completeness of the register of investors and their investments for the whole year
- contracts and subscription documentation
- evidence of the actual transfer of funds – according to the CNB, an investment is made only upon transfer, not by a mere commitment
- the amount of investments converted into EUR, including non-cash contributions
- the number of investors who do not meet the EUR 125,000 condition
Result
Auditor's report on verification of compliance with the investor limit
Ready for submission to the CNB. We perform the engagement as an assurance engagement under ISAE 3000 (Revised).
Key dates
1 July 2024
The ZISIF amendment (Act No. 163/2024 Coll.) takes effect. The new rules apply to newly registered entities.
1 July 2026
The transitional period ends. The rules also apply to entities registered earlier.
31 December 2026
End of the calendar year for which the limit is verified.
January–April 2027
The ideal time for the verification – with time to spare and without stress.
30 June 2027
The last day for submitting the auditor's report to the CNB.
How we work together
- 1.
Initial consultation
We discuss your structure, the number of investors and the documents available. We then promptly send you an offer with a fixed price and timeline.
- 2.
Documents
You send us the register of investors and supporting documents according to our list, electronically and securely.
- 3.
Verification
We verify the investments and the limit calculation. Any questions are resolved with you along the way, not at the very end.
- 4.
Auditor's report
You receive a signed report ready for submission – well ahead of 30 June.
What we will need from you
- identification of the venture capital entity and the structures it manages (e.g. SPVs, trust funds)
- the register of investors for the calendar year, including the amounts and dates of investments
- contracts and subscription documents
- bank statements evidencing the transfer of funds
- valuations of non-cash contributions, if any
- contact details of the person who keeps the register of investors
We will send you the complete list as a clear checklist.
Why AUDIT ÚČETNICTVÍ
A tradition since 1993
An audit firm licensed by the Chamber of Auditors of the Czech Republic (No. 075) with more than thirty years of practice.
We understand investment structures
We audit consolidated groups, holding structures and financial statements for bond issues.
A personal and discreet approach
We tailor the procedure specifically to you and keep you informed along the way. We treat your investors' data in confidence – as auditors, we are bound by statutory confidentiality.
Czech and English
We communicate in Czech and English.
Frequently asked questions
What is a venture capital entity?
A legal entity seated in the Czech Republic that, without a licence to manage investment funds, manages assets collected from investors for collective investment according to a defined strategy. It must be entered in the CNB list and, since Amendment No. 163/2024 Coll., its name must contain the phrase “osoba rizikového kapitálu” (venture capital entity). Such entities used to be called “Section 15 managers”.
By when must I submit the auditor's report?
By the end of the sixth month after the end of the calendar year, i.e. by 30 June. For 2026, by 30 June 2027 at the latest. You submit the report to the CNB electronically via SDAT (form DOFOS15).
Does this also apply to entities registered before 2024?
Yes. The 24-month transitional period following the amendment's entry into force ended on 1 July 2026. Since then, the condition of investing at least EUR 125,000, the 20-investor limit and the auditor's report obligation apply to everyone.
I have 20 investors or fewer. Do I need the report?
No. The law requires the auditor's report only if you have more than 20 investors. However, the other obligations under Section 15 ZISIF still apply to you.
Does an investor's commitment count towards the EUR 125,000?
According to the CNB's opinion, an investment is made only when the funds are actually transferred, not by a mere commitment. That is why we base the verification on evidence of the transfer.
How much does the verification cost?
The price depends mainly on the number of investors and on how you keep the register. After the initial consultation, we will send you an offer with a fixed price.
What other obligations do I have towards the CNB?
Every year by 31 January, you file a report on assets under management via SDAT (forms OFZ 36-01 and 37-01). The auditor's report is submitted separately, by 30 June.
Can you also provide a financial statement audit, tax or accounting services?
Yes. We are a full-service audit and advisory firm: audits of financial statements, consolidation, due diligence, tax advisory and bookkeeping. You will find an overview among our services.
This information is based on ZISIF as in force from 1 September 2026 and on CNB opinion RS2026-02. It does not constitute legal advice. Updated: October 2026.
Find out more about our services or discuss your situation with us
Leave us your contact details or contact our managing director, Vladimír Smolka.
Need more than Section 15? Audit, consolidation, tax and accounting
AUDIT ÚČETNICTVÍ, s.r.o. has been helping companies with financial statement audits, consolidation, due diligence, company transformations and tax advisory since 1993.
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