When I talk to first-time fund managers planning a launch in Austria, the same question comes up within ten minutes: "Do we need a full AIFM licence, or can we register?" It is a fair question, and the answer depends on how much capital you are raising, who your investors are, and whether you plan to market across borders. Austria's Alternative Investment Fund Managers Act (Alternatives Investmentfonds Manager-Gesetz, AIFMG) gives you both options, and for most emerging managers the registration path is where you start [1].
The distinction is not cosmetic. A fully licensed AIFM operates under the full weight of the AIFMD framework: capital requirements, depositary obligations, remuneration policies, detailed reporting. A registered AIFM has lighter obligations but real constraints. Getting this wrong at the outset can cost you six figures in unnecessary compliance spending or, worse, lock you out of your target investor base.
The thresholds that determine your path
The AIFMG draws a line based on assets under management. If your total AUM stays below EUR 100 million (including assets acquired through leverage), you qualify for registration rather than full licensing [1][3]. If you manage unleveraged closed-end funds with a lock-up period of at least five years, that ceiling rises to EUR 500 million [3].
For most first-time venture capital or private equity managers, these thresholds are comfortable. A Fund I raising EUR 20-50 million is well within bounds. But I have seen managers miscalculate by forgetting to include co-investment vehicles, side pockets, or other structures that aggregate into total AUM. The FMA (Finanzmarktaufsicht, Austria's financial regulator) looks at the full picture [1].
The 30-day rule. If your AUM crosses the threshold, you have 30 days to apply for a full licence [34]. That is not much time. You need your compliance infrastructure, governance documents, and capital reserves ready before you approach the line, not after. I tell every manager to build in a buffer and plan their threshold-crossing strategy at launch, even if they do not expect to hit it for years.
What registration actually requires
Registration is lighter than licensing, but it is not a rubber stamp. The FMA requires you to [34]:
- Prove the identity of the manager and its principals.
- Submit your investment strategy and details on the main instruments and exposures.
- Report annually on your principal trading instruments.
- Notify the FMA if your AUM approaches the thresholds.
What you do not need: a depositary appointment (though you may want one for investor confidence), the full AIFMD remuneration code, or the quarterly Annex IV reporting that eats up weeks for fully licensed managers. Your ongoing FMA fees are also lower. These savings compound when you are running a lean team.
What full licensing demands
If you need a full AIFM licence (because you exceed the thresholds, want to market to retail investors, or intend to use the AIFMD marketing passport), the requirements step up considerably.
Capital. You need initial capital of EUR 125,000 if you are an external manager (managing funds for third parties), or EUR 300,000 if the AIF is internally managed [3]. On top of that, you must maintain additional own funds equal to 0.02% of AUM above EUR 250 million, capped at EUR 10 million total. The FMA can require professional indemnity insurance as well.
Governance. Full licensing requires a depositary appointment, a risk management function that is functionally independent from portfolio management, and documented valuation procedures. You need a compliance officer, and your remuneration policy must align with AIFMD standards, including deferral requirements for variable compensation [3].
Reporting. Annex IV reporting to the FMA on a quarterly or semi-annual basis, depending on your AUM, covering leverage calculations, counterparty exposures, liquidity profiles, and risk metrics [21]. This is the single biggest recurring compliance burden for smaller managers.
Timeline. Expect the licensing process to take six to twelve months from a complete submission. During that time, the FMA will review your governance arrangements, conduct fit-and-proper assessments on key personnel, and may request supplementary information. Registration, by contrast, is typically a matter of weeks.
The EuVECA alternative
There is a third option worth mentioning for venture capital managers specifically. EuVECA (European Venture Capital Fund) registration gives you a cross-border marketing passport without full AIFM licensing, provided your fund meets specific criteria: at least 70% of capital must go into qualifying SME investments, and your investor base is limited to professional and semi-professional investors [9]. The FMA handles EuVECA registration, and six Austrian managers were registered as of the most recent data [30]. I wrote about this in more detail in a separate article on EuVECA in Austria.
Cross-border marketing: the licence advantage
This is where full licensing earns its cost. A fully licensed Austrian AIFM can use the AIFMD marketing passport to market to professional investors across the EU and EEA through a notification procedure [3]. You notify the FMA, the FMA notifies the host state regulator, and you are cleared to market within roughly 20 working days.
Registered AIFMs cannot use the passport. If you want to raise capital from German, French, or Dutch institutional investors, you are limited to each country's national private placement regime (NPPR), which varies in cost and complexity [40]. For a first fund targeting Austrian and possibly German investors only, this may be acceptable. For a fund with broader European ambitions, it is a real constraint.
I have worked with managers who launched as registered AIFMs for Fund I, built a track record, and then upgraded to full licensing for Fund II when cross-border marketing became a priority. That phased approach works well, provided you plan for it from the start.
Retail access requires full licensing
Another limitation of registration: you cannot market to retail investors in Austria. Article 49 of the AIFMG creates a pathway for AIFs to be marketed to retail investors, but it requires the fund manager to hold a full AIFM licence [25][46]. For venture capital managers, this is rarely a binding constraint since most LPs are institutional or high-net-worth individuals qualifying as professional clients. But if your strategy depends on reaching a broader retail audience, registration will not get you there.
The cost gap in practice
Let me put some numbers around this. For a first-time manager launching a EUR 30 million venture fund in Austria:
- Registered AIFM: Legal setup costs of EUR 15,000-30,000. FMA annual fees in the hundreds. No mandatory depositary cost. Annual reporting obligation is manageable in-house or with light external support. Total first-year regulatory overhead: EUR 25,000-50,000.
- Fully licensed AIFM: Legal setup costs of EUR 50,000-100,000. Initial capital of EUR 125,000. Depositary fees starting at EUR 15,000-30,000 annually. Compliance officer and risk management function. Annex IV reporting costs. FMA annual fees increase with AUM. Total first-year regulatory overhead: EUR 150,000-250,000.
That gap matters when your management fee income is EUR 450,000 on a EUR 30 million fund. Registration keeps you viable. Full licensing at that fund size requires either deep pockets or a very lean operation.
AIFMD II: what changes in April 2026
Austria is implementing AIFMD II with a deadline of April 16, 2026 [20]. The new rules introduce mandatory liquidity management tools for open-ended AIFs, a harmonized loan origination framework, and enhanced delegation transparency requirements. Both registered and fully licensed AIFMs will feel the impact, though fully licensed managers bear the heavier reporting burden.
For a manager deciding between registration and full licensing today, AIFMD II adds another variable. The compliance gap between the two paths is widening. If you register now, factor in that upgrading later means absorbing both the existing AIFM requirements and the AIFMD II additions simultaneously.
Making the decision
My framework for advising managers on this is straightforward:
- Register if your Fund I is under EUR 100 million (or EUR 500 million unleveraged/five-year lock-up), your investors are primarily Austrian or can be reached through NPPR, and you are comfortable limiting yourself to professional clients.
- License if you need the AIFMD marketing passport from day one, you are above the thresholds, or your strategy requires retail investor access.
- Plan the upgrade regardless. Even if you register now, structure your governance and documentation so that upgrading to full licensing for Fund II or Fund III is a matter of months, not a rebuild.
How Infra One supports Austrian fund launches
We work with emerging managers on both sides of this decision. Our fund administration platform handles the operational infrastructure (investor onboarding, capital calls, NAV calculations, regulatory reporting) whether you are registered or fully licensed. For registered AIFMs, we help you stay within the thresholds and prepare the annual reporting the FMA requires. For fully licensed managers, we handle the Annex IV reporting and depositary coordination that would otherwise consume your team's time.
If you are planning a fund launch in Austria and want to work through the licensing-vs-registration question with someone who has done it many times, get in touch.
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