Why This Matters
Access to private markets, pre-IPO shares, hedge funds, and most institutional-grade crypto products is closed to retail investors. The right to participate is determined not by account size per se, but by the investor's formal status in their jurisdiction. The same product may be open to a US qualified purchaser, a European professional client—and unavailable to a resident of a country without a corresponding regime.
USA: Accredited Investor and Qualified Purchaser
US federal law recognizes two thresholds. Accredited investor (Rule 501 Reg D)—income of $200,000 ($300,000 with spouse) for two consecutive years or net assets exceeding $1 million excluding primary residence; since 2020—also holders of Series 7/65/82 licenses. Qualified purchaser (Investment Company Act, §2(a)(51))—investment assets of $5 million or more for individuals; this threshold is higher and opens up funds under §3(c)(7) without a limit on the number of investors.
| Status | Threshold | What It Opens |
|---|---|---|
| Accredited investor | income $200k / assets $1 million | Reg D 506(b)/(c), most feeder structures |
| Qualified purchaser | investment assets $5 million+ | §3(c)(7) funds, direct institutional funds |
EU: Professional Client (MiFID II)
In the EU, the criterion is client categorization under MiFID II. Per se professional—banks, funds, large companies. Elective professional (on request)—an individual meeting two of three conditions: portfolio exceeding €500,000; relevant work experience in the financial sector; at least 10 significant transactions per quarter over the past year. Retail clients are not admitted to most alternatives—the exception is ELTIF 2.0, which since 2024 has opened private markets to retail subject to suitability assessment.
Switzerland, United Kingdom, and Offshore Jurisdictions
Switzerland—qualified investor under CISA: professional clients under FinSA plus high-net-worth individuals (assets from CHF 500,000 / 2 million and confirmed experience). United Kingdom—high-net-worth and sophisticated investor under FCA rules (thresholds raised in 2024: annual income £170,000 or net assets £430,000). Offshore funds (Cayman, BVI) typically rely on US and EU definitions directly in subscription documents.
What This Means in Practice
Status is confirmed at the subscription stage—by questionnaire, and under Reg D 506(c) in the US also by third-party verification. Citizenship and tax residency operate as a separate layer: a US person is restricted from accessing certain non-US products, and a non-US investor from US funds. Before a transaction, status is verified both for the product and the jurisdiction; the mechanics of the structures themselves are covered in Feeder fund and SPV.
🍓 Access to private markets is a matter of formal status, not just capital size. The US operates with accredited investor and qualified purchaser thresholds, the EU with professional client categorization under MiFID II, and these regimes are not interchangeable. The same fund may be open to an investor in one jurisdiction and closed in another—this is verified before subscription.
Key Factual Claims
- Switzerland—qualified investor under CISA: professional clients under FinSA plus high-net-worth individuals (assets from CHF 500,000 / 2 million and confirmed experience).
- Status is confirmed at the subscription stage—by questionnaire, and under Reg D 506(c) in the US also by third-party verification.