I walk managers through the Austrian fund launch process regularly, and the question I hear most often is: how long does this take, and what do I actually need to do myself? The answer depends on whether you go the sub-threshold registration route or pursue full FMA authorisation. But in either case, the process has a predictable shape. You set up a management company, form the fund vehicle, register with the FMA, appoint your service providers, onboard investors, and reach first close. The full timeline is typically 9 to 18 months from first conversation to first capital call [1].
What surprises most first-time managers is how much of this a fund services provider handles. The manager's job is to define the strategy, build the investor pipeline, and make investment decisions. Almost everything else — entity formation, regulatory filings, fund documentation, KYC/AML, NAV calculations, reporting — can be delegated to a team that does this every day.
Setting up the management company
The first concrete step is incorporating the AIFM entity. In Austria, this is almost always a GmbH (Gesellschaft mit beschränkter Haftung). Since January 2024, the minimum share capital for a GmbH is EUR 10,000, with at least EUR 5,000 paid in cash at incorporation — down from the previous EUR 35,000 [4]. The articles of association must be notarised before an Austrian notary, and if any founder does not speak German, a sworn interpreter is required [4].
After notarisation, you open a business bank account, deposit the share capital, and file for registration in the Commercial Register (Firmenbuch). Registration takes one to two weeks. Then come the follow-on registrations: trade licence, tax authority registration, social insurance, and automatic Economic Chamber membership [4]. We coordinate all of this for our clients. The manager provides the personal details and signs where needed.
Forming the fund vehicle
The standard Austrian fund structure is the GmbH & Co. KG — a limited partnership with a GmbH as general partner [5]. This is the same structure used across the German-speaking region. It gives you tax transparency at the fund level (income flows through to partners) and flexible governance that accommodates side letters and different investor classes [5]. We have a separate article on how carried interest is taxed under this structure.
In practice, you set up two GmbHs: one is the AIFM (the management company), and a separate one serves as the general partner of the fund vehicle. Both typically have the same managing directors. The fund itself — the KG — comes into existence when the first subscription agreements are signed and capital commitments start flowing in. We handle the entity structuring and coordination with the notary, so the manager can focus on the investment thesis and fundraising. For a deeper look at how the registration and licensing paths compare, we have a separate article.
Choosing between registration and full authorisation
This is the most important regulatory decision. Under the AIFMG, a manager can register as a sub-threshold AIFM if total AUM stays below EUR 100 million (for leveraged funds) or EUR 500 million (for unleveraged funds with no redemption rights for five years) [1]. Most emerging VC and PE managers in Austria qualify for registration on their first fund.
Registration is fast. A properly prepared notification can be submitted to and processed by the FMA within four to eight weeks. There is no formal authorisation procedure — the FMA records your status in its register. Professional fees for the registration route typically run EUR 15,000 to EUR 30,000 for legal counsel plus EUR 5,000 to EUR 15,000 for accounting work [1].
Full authorisation takes longer — eight to twelve weeks of preparation, then one to three months of FMA review — and costs EUR 50,000 to EUR 100,000 in professional fees. You need EUR 125,000 in own funds, a compliance officer, a risk manager, and a depositary in place before you apply [1]. The application itself is substantial: a business plan, risk management policy, organisational charts, CVs of key function holders, and copies of agreements with your depositary, administrator, and auditor [1]. The FMA will engage in active dialogue during the review and may request clarifications.
The upside of full authorisation is the AIFMD marketing passport for cross-border distribution and the ability to market to retail investors [2]. For managers who expect to raise larger follow-on funds or want to distribute across EU member states, it is the right long-term choice. For a first fund below EUR 100 million targeting Austrian and German family offices, registration gets you to market faster.
Appointing service providers
You need four key service providers before first close: a depositary bank, a fund administrator, an auditor, and legal counsel. We recommend selecting your depositary and administrator early — during business plan development, not after the FMA filing.
The depositary holds the fund's assets, monitors cash flows, and verifies compliance with investment restrictions. For PE and VC funds investing in unlisted companies, the depositary's role centres on record-keeping and oversight rather than physical custody of securities. In Austria, several major banks provide depositary services, including Bank Austria [1].
The fund administrator handles NAV calculations, investor accounting, capital call and distribution processing, regulatory reporting, and investor onboarding. Pricing for emerging managers typically runs EUR 40,000 to EUR 100,000 per year on a fixed-fee basis, depending on investor count and reporting frequency [1]. Many managers opt to engage their depositary and administrator from the same banking group, since the two work closely together and shared infrastructure reduces operational friction.
An independent auditor (Wirtschaftsprüfer) conducts the annual fund audit. The big four all have Vienna offices, but several mid-sized Austrian firms provide high-quality fund audit services at lower cost. Specialised legal counsel handles the FMA application, fund documentation, and the LPA. We recommend engaging counsel experienced in Austrian fund law at the earliest stage of planning — before the business plan is finalised — to avoid structural choices that create problems later.
Fund documentation and investor terms
Before you can accept commitments, you need a private placement memorandum (PPM) and a limited partnership agreement (LPA). The PPM describes the investment strategy, fees, risks, and governance. The LPA is the controlling agreement — it governs capital calls, distributions, carry calculations, investor voting, and dissolution [5].
For funds distributed only to professional and semi-professional investors, Austrian law does not require a prospectus, provided the offering meets private placement exemptions under the Capital Market Act [5]. Many managers still prepare simplified prospectuses voluntarily because institutional investors expect them. If you do plan to market to retail investors, you need to comply with AIFMG Article 49 requirements including a Key Investor Information Document and evidence of investor protection measures [1].
Under AIFMD II, which Austria transposed in April 2026, there are new documentation requirements around loan origination (20% single-borrower concentration limits, ban on originate-to-distribute strategies), liquidity management tools, and delegation transparency [17]. The reform also tightened delegation oversight: AIFMs must now provide granular detail about delegated functions and the resources retained to supervise delegates, with ESMA maintaining a centralized delegation database for EU-wide monitoring [17]. Even if your fund does not originate loans, the liquidity management disclosures now apply to all AIFs. For standard equity VC and PE funds, the practical impact of AIFMD II is manageable, but the documentation needs to address it.
Investor onboarding and KYC/AML
Austrian AML obligations come from the Financial Markets Anti-Money Laundering Act and the Banking Act. Every investor must go through identity verification, beneficial ownership checks (tracing through to natural persons holding more than 25% of voting rights or beneficial interests), and source-of-funds verification [21]. For politically exposed persons, enhanced due diligence and senior management sign-off are required [22].
We run the full onboarding process: investor questionnaires, document collection, beneficial ownership verification, sanctions screening, and ongoing monitoring. Each investor gets a complete AML/KYC file that is audit-ready from day one. For corporate and institutional investors, we trace through the ownership chain. For trust structures, Austrian law requires in-person identification of trustees — remote verification is not permitted in that case [21].
Semi-professional investors — those committing at least EUR 100,000 and meeting suitability criteria — are a useful category in Austria. They widen the LP pool beyond purely professional investors without triggering retail-level disclosure requirements.
First close and capital deployment
Typical first-fund targets in Austria range from EUR 50 million to EUR 250 million, with most emerging managers aiming for EUR 75 million to EUR 150 million [5]. Minimum investor commitments are usually set between EUR 250,000 and EUR 1,000,000 for institutional LPs, or as low as EUR 100,000 to capture semi-professional investors. Setting the minimum too low creates an administrative burden with many small LPs; setting it too high shrinks the pool. For first-time managers with limited investor relations capacity, EUR 500,000 to EUR 1,000,000 is usually the right range.
First close is the point where enough commitments are in to start operations — typically 50 to 75% of the target fund size, achieved within 6 to 12 months of starting fundraising [5]. At first close, the KG becomes effective, the first capital call goes out, and the reporting cycle begins.
Before first close, several operational pieces need to be in place: the fund bank account (a restricted, segregated account where funds are released only with joint signatures from the manager and depositary), the depositary agreement, professional indemnity insurance, and the administrative infrastructure for processing capital calls and maintaining the investor register. We set all of this up as part of the fund formation process.
Ongoing compliance and reporting
After first close, the fund enters a continuous compliance cycle. Registered AIFMs file simplified annual reports with the FMA. Fully authorised AIFMs report quarterly (if AUM exceeds EUR 500 million), semi-annually (EUR 100 million to EUR 500 million), or annually (below EUR 100 million) using the AIFMD Annex IV format [2]. These reports cover portfolio composition, leverage, counterparty exposure, and liquidity profiles.
The fund itself must prepare annual audited financial statements by an independent Wirtschaftsprüfer, annual investor reports covering performance and fees (required under AIFMG Articles 20 and 21), and tax filings through an Austrian tax representative who reports to the Oesterreichische Kontrollbank [20]. For fully authorised AIFMs, there is also an annual compliance certification to the FMA confirming continued capital and governance adequacy, plus periodic FMA examinations covering risk management, delegation, and conflicts of interest [1].
We handle all of this — the AIFMD reporting, the audit coordination, the investor reports, the tax filings — as part of ongoing fund administration. The manager reviews and approves, but the operational work is ours.
FMA annual fees are modest: EUR 600 per fund for registered AIFMs, EUR 600 for authorised AIFMs marketing to professional investors, or EUR 1,200 if marketing to retail investors [3].
What we handle at Infra One
We run the end-to-end fund launch process for Austrian managers. That means: incorporating the GmbH entities, forming the GmbH & Co. KG fund vehicle, preparing and filing the FMA registration or authorisation application, drafting fund documentation (PPM, LPA, subscription agreements), coordinating depositary and auditor appointments, running investor onboarding with full KYC/AML, processing capital calls and distributions, calculating NAV, preparing regulatory and investor reports, and coordinating annual audits and tax filings.
The manager's job is the strategy, the deal pipeline, and the investor relationships. Everything else runs through our fund platform. If you are planning a fund launch in Austria and want to understand what the timeline and process look like for your specific situation, get in touch.
DISCLOSURE: This communication is on behalf of Infra One GmbH ("Infra One"). This communication is for informational purposes only, and contains general information only. Infra One is not, by means of this communication, rendering accounting, business, financial, investment, legal, tax, or other professional advice or services. This publication is not a substitute for such professional advice or services nor should it be used as a basis for any decision or action that may affect your business or interests. Before making any decision or taking any action that may affect your business or interests, you should consult a qualified professional advisor. This communication is not intended as a recommendation, offer or solicitation for the purchase or sale of any security. Infra One does not assume any liability for reliance on the information provided herein. © 2026 Infra One GmbH All rights reserved. Reproduction prohibited.