The crowdfunding exemption is granted in exchange for continuing obligations, and most failures happen after the money is raised rather than before. Annual reports, progress updates, material-change disclosure, investor-limit enforcement and records that survive examination are all ongoing duties.
We run those obligations as an operating function. A disclosure calendar, an issuer-onboarding and monitoring process for platforms, a supervisory review cycle, and the records and reporting that let you demonstrate compliance when it is tested.
The engagement suits both issuers carrying their post-close duties and platforms that need a repeatable compliance function across many simultaneous offerings.
- You have completed a crowdfunded raise and are unsure what you now have to report.
- You operate a portal with several live offerings and no repeatable compliance process.
- Investor-limit enforcement is handled per campaign rather than per investor.
- You have an examination or a platform review approaching and cannot produce the records.
The clock starts at close
Reporting obligations begin once the raise completes and continue for at least a year. Treating the close as the end of the project is how issuers fall into breach.
Limits must be enforced across offerings
A platform enforces investor limits in aggregate, not per offering. That requires an investor-level view and records, not a campaign-level one.
Demonstrable, not merely intended
The test is whether the platform can produce the records showing the process was followed. Procedures without evidence do not satisfy a review.
- Ongoing disclosure calendar and reporting templates
- Annual report and progress-update workflow
- Issuer onboarding, review and monitoring process for platforms
- Investor-limit enforcement and aggregate record-keeping design
- Supervisory review, exception handling and escalation procedures
- Examination-readiness file and records-retention framework
- 01
Inventory the obligations
What the issuer or platform must disclose, when, and to whom — mapped against the actual live offerings.
- 02
Build the calendar
A reporting schedule with owners and templates, so obligations are recurring tasks rather than reminders.
- 03
Instrument the controls
Limit enforcement, issuer review and exception handling built into the platform’s operating process.
- 04
Create the evidence
Records, logs and review notes that demonstrate the process operated, assembled as a by-product of doing the work.
- 05
Review and sustain
A periodic supervisory review cycle, so the function stays current as offerings and volumes change.
Obligations and gaps review
A written assessment of your continuing duties and where the current process falls short of them.
Compliance function build
Calendar, controls, records and supervisory cycle implemented as a repeatable operating function.
Examination readiness
Focused preparation of the records and evidence for an anticipated review or examination.
- Issuers looking to minimise disclosure below what the regime requires — the exemption depends on it.
- Platforms seeking a compliance narrative rather than the records that evidence it.
At minimum an annual report with the specified financial and business information, plus disclosure of material changes as they occur, generally for at least the year following the raise. The specific content depends on the raise size and the issuer, and we set the calendar to match your obligations rather than a generic checklist.
By maintaining investor-level records across all offerings on the platform and checking each investment against the applicable annual limit, based on the investor’s income and net worth representations. The check has to be aggregate, which means the data model matters as much as the procedure.
The issuer is in breach of the conditions on which the exemption was granted, which is a serious position, and the platform has an interest in the issuer complying. That is why the issuer-monitoring process exists: to detect a lapse early enough to act, rather than at the review.
Yes. We frequently start with a gap assessment of the current framework, then rebuild the calendar, controls and records around how the platform actually operates — which is usually more durable than importing procedures from elsewhere.