What Does It Cost to Set Up a Wholesale Fund in Australia?

"What will it cost?" is usually the second question an emerging manager asks, right after "do I need a licence?". The answer turns almost entirely on one decision: whether you set the fund up under an existing AFSL, or apply for your own. Same fund, same strategy — but the two routes are separated by tens of thousands of dollars, a $150,000 capital requirement, and the better part of a year.

The decision that drives the cost

To operate a wholesale fund lawfully you generally need to be covered by an AFS licence — and, as we cover in own AFSL vs authorised representative, there are only two ways to get there:

• Set up under an existing AFSL. You're appointed as a corporate authorised representative to run the strategy, and the licensee acts as trustee and issuer of the scheme.
• Apply for your own AFSL. You hold the licence — and everything that comes with it.

Everything else — the deed, the offer document, the structuring advice — follows from that choice. So does the bill.

Option 1 — Under an existing AFSL: $20,000–$60,000

Setting up a wholesale fund under an existing AFSL typically costs $20,000 to $60,000. That covers standing the fund itself up:

• The fund vehicle and trust deed that constitute it.
• The information memorandum used to offer interests to wholesale investors.
• The operational onboarding needed before you can accept investors.

Because the licence already exists, there's no application to fund, no responsible managers to recruit, no compliance framework to build from scratch, and no NTA for you to hold — those sit with the licensee.

What it doesn't include: ongoing fees and charges, which are billed separately — and any separate legal and tax advice your structure requires, which sits outside this fee. Budget for both from day one.

Option 2 — Your own AFSL: $60,000–$100,000, plus $150,000 in NTA, plus eight months

Applying for your own AFSL typically costs $60,000 to $100,000 to set up. But the sticker price is the least of it. Two things bite harder.

The $150,000 you can't spend

You must hold an additional $150,000 in net tangible assets. ASIC sets the financial requirements for AFS licensees — including NTA — in RG 166 AFS licensing: Financial requirements.

This is worth understanding properly, because NTA is routinely misread as a fee. It isn't. NTA is capital that must sit on your balance sheet and stay there. For a manager raising a first fund, that's $150,000 of your own money you cannot deploy into the strategy, cannot use as working capital, and cannot release while you hold the licence. The exact requirement depends on your authorisations and the nature of the scheme — check RG 166 and confirm what applies to you.

At least eight months of waiting

An AFS licence application is assessed by ASIC and generally takes at least eight months (see ASIC: RG 1 for what's assessed and why timelines vary). That's eight months in which the strategy isn't running, investors are waiting, and no fee clock has started. For most emerging managers, the time cost dwarfs the licence cost.

And what the $60,000–$100,000 still doesn't cover

• Your ongoing compliance requirements — the framework, the monitoring, the reporting.
• Your key persons.
• Your responsible managers, whom you must nominate and maintain — and whose remuneration is a real, recurring cost if they're external.

So the honest cost of self-licensing is: the setup figure, plus locked-up capital, plus a compliance function, plus people — plus the eight months.

The two routes, side by side

What moves you within the range

Whichever route you take, three things determine where you land.

1. Your investment strategy

What the fund actually invests in drives the complexity of the structure and the advice around it. A private credit fund and a property fund don't raise the same structuring, security, valuation or tax questions, and the documentation follows the strategy.

2. Who your investors are

A fund raised solely from domestic wholesale investors is generally simpler, and sits at the lower end. As soon as the structure needs to work for foreign investors — who sit outside the Australian tax system — you're into additional tax and legal advice, and sometimes a different or additional vehicle. That pushes you up the range.

3. How much expert advice you need

Some structures are well-trodden and can be documented efficiently. Others need specialist input from the outset. The more the structure demands, the further up the range you'll sit.

Where an integrated platform fits

The gap between those two columns isn't really about paperwork. It's that self-licensing asks an emerging manager to fund a licence, lock up $150,000, appoint responsible managers and build a compliance function — all before earning a cent of fees, and eight months before the strategy can run.

Provenance removes that layer. Providence Equity Holdings provides the licence, the trustee and issuer infrastructure, and the compliance and operational framework, so you can be authorised and in-market in weeks rather than months. We work to a fixed engagement fee, so the cost of the licensed layer is known up front rather than metered — and because we've done it before, the launch is executed rather than learned.

You still build your own offering, brand and client relationships. What you don't do is spend the better part of a year, and six figures, buying the right to start.

Frequently asked questions

Related reading: How to set up a wholesale fund in Australia — the eight steps, in order. And own AFSL vs authorised representative — the two paths to market, compared. And do corporate advisors need an AFSL? — when advice and arranging trigger a licensing requirement.

Sources & further reading (ASIC)

This page draws on guidance published by ASIC. Fees and requirements change — for the authoritative and current position, see:

Disclaimer