Sub-threshold Alternative Investment Fund Manager registration (Czech Republic)
The Sub-threshold Alternative Investment Fund Manager registration pursuant to Section 15 of AMCIF (zápis osoby provádějící správu majetku srovnatelnou s obhospodařováním podle § 15 ZISIF) is issued by Czech National Bank (CNB) under Act No. 240/2013 Coll. on Management Companies and Investment Funds. It is a national licence: it does not give a passport to other EU/EEA states. The official register lists 458 current holders. The application fee is CZK 10,000.
At a glance
| Official name | Sub-threshold Alternative Investment Fund Manager registration pursuant to Section 15 of AMCIF1 |
|---|---|
| Local name | zápis osoby provádějící správu majetku srovnatelnou s obhospodařováním podle § 15 ZISIF |
| Also known as | Sub-threshold AIFM · Registered AIFM · Czech sub-threshold AIFM registration · § 15 ZISIF registration |
| Issued by | Czech National Bank |
| Jurisdiction | Czech Republic |
| Licence family | Fund manager |
| Legal basis | Act No. 240/2013 Coll. on Management Companies and Investment Funds1 Regulation (EU) 2020/1503 on European crowdfunding service providers for business2 Directive 2011/61/EU on Alternative Investment Fund Managers (AIFMD)3 |
| Passporting | Domestic only |
| Application fee | CZK 10,0004 |
| Statutory decision time | 30 days (general administrative code deadline)1 |
| Public register | official register5 |
| Current holders | 4585 |
What it lets you do
| Managing alternative investment funds | Performing portfolio management and risk management for funds that are not UCITS, such as hedge, private equity and real estate funds. |
|---|
Where it is valid
Cost
How long it takes
Statutory: 30 days (general administrative code deadline)1. Observed: not published. The statutory clock usually starts only when the regulator treats the application as complete, and pauses while it waits for answers to its questions.
Buying a company that already holds it
Prior notification with an objection period. Under Section 18 of the Payment Systems Act (Act No. 370/2017 Coll.), any person or persons acting in concert intending to acquire, dispose of, or increase a qualifying holding in a payment institution or electronic money institution reaching or exceeding 20%, 30%, or 50% of voting rights or capital, or become the controlling person, must notify the CNB in advance via electronic filing. The CNB assesses the trustworthiness and suitability of the proposed acquirer within a statutory 60-working-day window and may initiate proceedings to issue a formal objection (vyslovení nesouhlasu). In the absence of an objection or upon affirmative notification, the acquisition may proceed. Acquiring qualifying holdings in breach of notification or objection leads to statutory forfeiture of voting rights. In contrast, for banks and investment firms under Act No. 21/1992 Coll. and Act No. 256/2004 Coll., prior approval (předchozí souhlas) is required subject to a CZK 20,000 fee under Item 66 of Act No. 634/2004 Coll. Small-scale providers (PPSMR/VEPMR) are exempt from change-of-control clearance.6
FM in other countries
| Country | Licence | Regulator | Min. capital | Application fee | Statutory time |
|---|---|---|---|---|---|
| Abu Dhabi Global Market (ADGM) | Fund manager licenceFinancial Services Permission for Managing a Collective Investment Fund (Category 3C) | FSRA | n/a | n/a | n/a |
| Bermuda | Fund Administrator LicenceFund Administrator Licence (Part III, Investment Funds Act 2006) | BMA | n/a | n/a | n/a |
| British Virgin Islands | Fund manager licenceBVI mutual fund recognition (private/professional fund), registration (public fund) or approval (incubator/approved fund) - funds are recognised/registered/approved, not 'licensed' | BVI FSC | n/a | n/a | n/a |
| Cayman Islands | Regulated Mutual FundRegulated Mutual Fund (registered, master, or administered fund under the Mutual Funds Act) | CIMA | n/a | n/a | n/a |
| Cayman Islands | Registered Private FundRegistered Private Fund under the Private Funds Act | CIMA | n/a | n/a | n/a |
| Cyprus | Alternative Investment Fund Manager (AIFM) authorisation | CySEC | n/a | n/a | ~3 mo |
| Cyprus | Sub-threshold Alternative Investment Fund Manager registration | CySEC | n/a | n/a | n/a |
| Cyprus | UCITS Management Company authorisation | CySEC | n/a | n/a | n/a |
| Czech Republic | Sub-threshold Alternative Investment Fund Manager registrationSub-threshold Alternative Investment Fund Manager registration pursuant to Section 15 of AMCIF | CNB | n/a | CZK 10,000 | ~1 mo |
| Czech Republic | Investment Company / Fund Manager licence | CNB | n/a | CZK 50,000 | ~6 mo |
| Dubai International Financial Centre (DIFC) | Fund manager licenceFinancial Services Permission for Managing a Collective Investment Fund (Category 3C) | DFSA | n/a | USD 10,000 | n/a |
| Estonia | Small fund manager registration without activity licence | FI | n/a | n/a | n/a |
| Estonia | Operating licence as a fund management company | FI | n/a | EUR 600 | n/a |
| France | Portfolio management company authorisation | AMF | n/a | n/a | ~3 mo |
| Germany | Investment management company licence | BaFin | n/a | n/a | n/a |
| Ireland | Alternative Investment Fund Manager (AIFM) Authorisation/Registration | CBI | n/a | n/a | n/a |
| Ireland | UCITS Management Company Authorisation | CBI | n/a | n/a | n/a |
| Luxembourg | Alternative investment fund manager (AIFM) authorisation | CSSF | n/a | EUR 18,000 | ~3 mo |
| Luxembourg | Management company authorisedManagement company authorised under Chapter 15 of the Law of 17 December 2010 | CSSF | n/a | EUR 18,000 | ~6 mo |
| Netherlands | Alternative Investment Fund Manager (AIFM) licenceAlternative Investment Fund Manager (AIFM) licence under Wft Article 2:65 and Directive 2011/61/EU | AFM | n/a | EUR 200 | ~6 mo |
| Netherlands | Fund manager licenceUndertakings for Collective Investment in Transferable Securities (UCITS / ICBE) registration under Wft and Directive 2009/65/EC | AFM | n/a | n/a | n/a |
| Poland | Investment Fund Company licence | KNF | n/a | n/a | n/a |
| Poland | Alternative Investment Company Manager registration / licence | KNF | n/a | n/a | n/a |
| Seychelles | Fund Administrator's LicenceFund Administrator's Licence (and Restricted Fund Administrator's Licence) under the Mutual Fund and Hedge Fund Act 2008 | FSA | n/a | n/a | n/a |
| Spain | Fund manager licence (SGIIC) | CNMV | n/a | EUR 10,000 | n/a |
| Switzerland | Fund management company licence | FINMA | n/a | n/a | n/a |
| Switzerland | Manager of collective assets licence | FINMA | n/a | n/a | n/a |
| United Kingdom | Fund manager licenceAlternative Investment Fund Manager (AIFM) Authorisation / Registration | FCA | n/a | n/a | n/a |
Values come from each licence's page, where every figure has its source.
Laws behind it
- European Crowdfunding Service Providers Regulation: Regulation (EU) 2020/1503
- Alternative Investment Fund Managers Directive: Directive 2011/61/EU
Sources
- Czech legislation (Zákony pro lidi): 2013 240 · retrieved 2026-09-24
- EUR-Lex: CELEX 32020R1503 · retrieved 2026-09-24
- EUR-Lex: CELEX 32011L0061 · retrieved 2026-09-24
- Czech legislation (Zákony pro lidi): 2004 634 · retrieved 2026-09-24
- cnb.cz: fms 2024 (PDF) · retrieved 2026-09-24
- Czech legislation (Zákony pro lidi): 2017 370 · retrieved 2026-09-24
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