How to raise a VC fund in Portugal
Short answer
What does it take to raise a first VC fund in Portugal?
Raising a venture fund in Portugal means operating under the Regime da Gestão de Ativos introduced by Decreto-Lei n.º 27/2023, supervised by the CMVM, within the EU alternative investment fund framework. Smaller managers often use the EuVECA regime under Regulation (EU) No 345/2013 to market across the European Union.
Portugal sits inside the EU fund passporting framework, which is the single most important fact for a first time manager. The domestic regime was consolidated by Decreto-Lei n.º 27/2023 into the Regime da Gestão de Ativos, and the CMVM supervises managers and vehicles under it. For a sub-scale first fund, the EuVECA regime is often the pragmatic route to marketing across the Union.
The series for Portugal
Part 1. Getting money in the door
13 minA first Portuguese venture fund operates under the Regime da Gestão de Ativos introduced by Decreto-Lei n.º 27/2023 and supervised by the CMVM. Smaller managers commonly use the EuVECA regime under Regulation (EU) No 345/2013 to market across the European Union without full AIFMD authorisation.
Part 2. Diligence and deal flow
11 minA first-time Portuguese manager wins on process, not headcount. Publish a written thesis, triage every inbound against it within a fixed window, source deliberately through operator networks, and record the evidence behind each investment committee decision so the reasoning survives the fund's ten year life.
Part 3. Running the fund post-close
12 minAfter final close the job changes from raising to operating. A Portuguese manager runs capital calls and distributions in EUR, applies a written valuation policy consistently, reports to LPs on a fixed cadence, answers due diligence questionnaires, and meets audit and the CMVM obligations without a large back office.
The full Portugal checklist
Every step from all three parts on one printable page.
The vehicles available in Portugal
Portuguese alternative investment fund under the Regime da Gestão de Ativos
Decreto-Lei n.º 27/2023 consolidated the Portuguese asset management regime, including venture capital vehicles, under a single framework supervised by the CMVM.
Decreto-Lei n.º 27/2023EuVECA qualifying venture capital fund
An EU-level regime designed for smaller venture managers, allowing a registered manager to market a qualifying fund across the Union under the EuVECA designation.
Regulation (EU) No 345/2013Full-scope AIFM
Managers above the AIFMD thresholds are subject to the full authorisation regime, which brings the EU marketing passport with it.
Directive 2011/61/EU (AIFMD)Which vehicle fits
Do you expect to market the fund outside Portugal?
Indicative only. Vehicle selection in Portugal is a legal question for the fund's counsel. Reuben AI does not provide legal or tax advice.
Read every branch as text
Do you expect to market the fund outside Portugal?
- Yes, across the European Union
- No, Portuguese investors only
Is the fund small enough to sit below the AIFMD thresholds?
- Yes, a sub-scale first fund
- No, or unsure
Portuguese alternative investment fund under the Regime da Gestão de Ativos
A domestic-only fund is constituted and supervised under Decreto-Lei n.º 27/2023, with the manager registered or authorised with the CMVM according to its scale.
EuVECA qualifying venture capital fund
Regulation (EU) No 345/2013 creates a regime designed for smaller venture managers, allowing a registered manager to market a qualifying fund to eligible investors across the Union under the EuVECA designation.
Full-scope AIFM with the AIFMD marketing passport
Managers above the AIFMD thresholds are subject to full authorisation under Directive 2011/61/EU, which carries the EU marketing passport for professional investors.
When managing a fund triggers a licence
Managing an alternative investment fund in Portugal requires the manager to be registered or authorised with the CMVM under the Regime da Gestão de Ativos, with the sub-threshold or full-scope AIFMD position determined by the manager's assets under management. Smaller venture managers can alternatively register under the EuVECA regime.
Who the limited partners are
- European Investment Fund
- The EIF is a cornerstone investor in European venture funds and a familiar anchor for first time managers across the Union, including Portugal. European Investment Fund
- National promotional bank
- Banco Português de Fomento is Portugal's national promotional bank and operates instruments directed at Portuguese companies and funds. Banco Português de Fomento
- State venture arm
- Portugal Ventures invests in Portuguese startups and is part of the domestic innovation financing landscape. Portugal Ventures
- Family offices and individuals
- Portuguese family capital and successful founders are a meaningful source of first fund commitments, typically through relationships rather than process.
- Cross-border European LPs
- Because Portugal is inside the EU framework, a properly structured fund can market to professional investors across the Union, which widens the addressable LP base considerably. ESMA: registers and data
- Corporates
- Portuguese corporates invest as LPs where the fund thesis maps to their sector, and increasingly alongside funds as co-investors. APCRI
Segments are unweighted. No official register in this jurisdiction publishes a breakdown of limited partner capital by segment, so we do not imply proportions.
Foreign investors
Marketing to professional investors elsewhere in the European Union depends on the manager's regime. Full-scope AIFMs use the AIFMD marketing passport. EuVECA registered managers market qualifying funds under Regulation (EU) No 345/2013. Marketing outside the Union is a national private placement question in each target country.
Incentives and support programmes
Portuguese fund and investor taxation is fact specific and depends on the vehicle, the investor's residence and applicable treaties. We do not publish rates here because they cannot be stated accurately without knowing your structure. Confirm with Portuguese tax counsel before marketing any tax position to LPs.
The sequence from thesis to final close
- 1.Thesis and track record. Written thesis, evidenced track record and a clear European angle.
- 2.Regime decision. Sub-threshold, EuVECA or full-scope AIFMD, decided with counsel.
- 3.CMVM registration or authorisation. Manager registered or authorised with the CMVM under the Regime da Gestão de Ativos.
- 4.Service provider selection. Depositary, administrator and auditor appointed as the regime requires.
- 5.Fund documentation. Constitutional documents and investor disclosures drafted with Portuguese counsel.
- 6.Anchor commitment. Cornerstone conversation with a promotional or EU-level investor progressed.
- 7.First close. Fund constituted and marketing route confirmed for each target country.
- 8.Deployment and reporting. Investor reporting and CMVM obligations begin.
Sequence only. We do not publish indicative durations because the regulators covered in this series do not publish fixed timeframes for these steps.
Who regulates this in Portugal
Primary sources. Always confirm against the regulator's current text before you rely on it.
Primary regulator
CMVM (Comissão do Mercado de Valores Mobiliários)Supervises fund managers and collective investment vehicles in Portugal.
Questions managers ask about Portugal
- Who regulates venture capital funds in Portugal?
- The CMVM, the Comissão do Mercado de Valores Mobiliários, supervises asset managers and funds in Portugal under the Regime da Gestão de Ativos introduced by Decreto-Lei n.º 27/2023.
- What is the Regime da Gestão de Ativos?
- It is the consolidated Portuguese asset management framework introduced by Decreto-Lei n.º 27/2023, which brought venture capital and other collective investment vehicles under a single regime supervised by the CMVM.
- Can a Portuguese venture fund market across the European Union?
- Yes, subject to the manager's regime. Full-scope AIFMs use the AIFMD marketing passport under Directive 2011/61/EU. Smaller managers can register a qualifying fund under the EuVECA regime in Regulation (EU) No 345/2013.
- What is EuVECA and why does it matter for a first fund?
- EuVECA is an EU regime under Regulation (EU) No 345/2013 designed for smaller venture capital managers. It lets a registered manager market a qualifying venture fund to eligible investors across the Union without full AIFMD authorisation.
- Who are the typical anchor LPs for a first Portuguese venture fund?
- The European Investment Fund, Banco Português de Fomento as the national promotional bank, Portugal Ventures, Portuguese family offices and founders, and corporates whose sector maps to the fund thesis.
Revision history
- 2026-07-28First publication. Regime, regulator and EU framework verified against CMVM, Diário da República and EUR-Lex.
General information for fund managers, not legal, tax or financial advice. Fund structuring, licensing and marketing rules turn on your specific facts. Confirm the current position with CMVM (Comissão do Mercado de Valores Mobiliários) and take advice from counsel qualified in Portugal.
Cite this guide
Free to quote and link. Please cite the permalink and the review date.
Katriona Lee. "How to raise a VC fund in Portugal." Reuben AI, 2026. Last reviewed 2026-07-28. https://www.goreuben.com/guides/raise-a-vc-fund/portugal
- Publisher
- Reuben AI
- Author
- Katriona Lee
- Last reviewed
- 2026-07-28