Reserved Italian AIFs – Amendments to DM no. 30/2015 and establishment of new minimum investment thresholds for retail investors

Prepared by Fabrizio Cascinelli, Anna Di Vilio and Silvia Benincasa

On 15 March 2022, Decree no. 19 of the 13 January 2022 of the Ministry of Economy and Finance (“MEF“) relating to the Regulation amending Decree no. 30 of 5 March 2015 was published in the Italian Official Gazette (hereinafter the “Decree”).

The MEF issued the Decree following the end of the public consultation process launched on 4 June 2020 and falls within a framework of stimulating financing for the real economy, addressing the eligibility criteria that investors must meet for subscribing Italian reserved AIFs.

The Decree thus reflects the need to broaden the range of retail investors, with medium/large assets, willing to invest in the medium/long term in illiquid assets and in unlisted companies, in order to diversify their financial portfolio, achieve an appreciable return, finance Italian companies and with them the economic recovery of the Country.

In particular, in addition to retail investors subscribing or purchasing units or shares of the AIF for a total amount of not less than five hundred thousand, the Decree intervenes by providing that the rules or the by-laws of the reserved Italian AIF may also provide for the participation of the following parties:

  • retail investors who, within the provision of the investment advice service, subscribe or purchase units or shares of the AIF for an initial amount of not less than Euro one hundred thousand, provided that, as a result of the subscription or purchase, the total amount of investments in reserved AIFs does not exceed 10% of their financial portfolio. The minimum initial shareholding cannot be split up;
  • persons authorised to provide portfolio management services who, in the performance of such service, subscribe or purchase units or shares of the AIF for an initial amount of not less than one hundred thousand euros on behalf of retail investors.

The definition of “financial portfolio” is also introduced, intended as the overall value of the portfolio made up of bank deposits, insurance investment products and financial instruments also available from other intermediaries or asset management companies.

The above-mentioned definition is particularly relevant for the purpose of verifying – on behalf of the parties proposing the purchase or subscription of units or shares of reserved Italian AIF – the eligibility of retail investors.

Finally, the possibility of subscribing units or shares of reserved Italian AIFs, even below the aforementioned thresholds, has been extended, in general, to all the personnel of the asset management company, meaning both the employees – as already provided for before the amendment along with the members of the Board of Directors of the asset management company – as well as those who in any case operate on the basis of a business relationship that determines their inclusion in the asset management company’s organisation, also in a form other than an employment relationship.

The Decree, which thereby opens up new business opportunities for the stakeholders of the asset management sector, will enter into force on 30 March 2022.

Let’s Talk

For a deeper discussion, please contact:

Fabrizio Cascinelli

PwC TLS Avvocati e Commercialisti


Anna Di Vilio

PwC TLS Avvocati e Commercialisti



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