Reuben AI

    Continuation Funds in Australia

    A continuation fund moves one or more assets out of an existing fund into a new vehicle, so the sponsor can hold them longer. Existing investors elect to roll into the new vehicle or take liquidity, and new capital funds those who exit.

    GP-led secondaries and continuation vehicles with rollover mechanics, LP election tracking and audit-ready governance across the transaction lifecycle.

    Australian private capital uses VCLP, ESVCLP or VILP partnerships registered under the Venture Capital Act 2002, CCIVs under the 2022 CCIV framework, or unit trusts operated as Managed Investment Schemes supervised by ASIC. Fund managers of wholesale MIS and CCIVs typically hold an AFSL from ASIC, with MIT and AMIT elections available for eligible trusts.

    How continuation funds are actually run

    Continuation transactions are the most governance-heavy structure in private markets, because the sponsor sits on both sides. The manager is selling an asset it also intends to keep managing, and the price it accepts determines the outcome for the investors it advises. Every step of that process needs to be documented as it happens.

    Operationally, the hard part is the election. Each investor makes an individual choice under a deadline, and the resulting register on day one of the new vehicle is a function of hundreds of separate decisions. Reuben AI runs the election as structured data, so the rollover register, the cash-out schedule and the new vehicle's opening position are computed rather than assembled.

    Regulatory framework

    Jurisdiction: Australia (AU) · AUD
    Common local fund structures: Managed Investment Scheme (MIS) under the Corporations Act 2001, Wholesale Unit Trust for wholesale clients under the Corporations Act 2001, Venture Capital Limited Partnership (VCLP) under the Venture Capital Act 2002, Early Stage Venture Capital Limited Partnership (ESVCLP) under the Venture Capital Act 2002, Venture Capital Incorporated Limited Partnership (VILP/ILP) under state Partnership Act frameworks, Corporate Collective Investment Vehicle (CCIV) under the Corporations Amendment (Corporate Collective Investment Vehicle Framework and Other Measures) Act 2022, Managed Investment Trust (MIT) under Division 275 of the Income Tax Assessment Act 1997, Australian Fund of Funds (AFOF) under the Venture Capital Act 2002, Family or discretionary trust regulated by the ATO, Self-Managed Super Fund (SMSF) regulated by the ATO

    Local structuring, tax and regulatory advice is the responsibility of the fund's counsel and administrator. Reuben AI does not provide legal or tax advice.

    How Reuben AI supports Continuation Funds in Australia

    What the manager has to keep straight

    Election tracking

    Roll, partial roll or cash out captured per investor, with deadlines, reminders and a complete audit trail.

    Conflict record

    Valuation basis, third-party inputs, committee approvals and investor consents recorded in sequence.

    Opening register

    The new vehicle's register generated directly from elections rather than rebuilt by hand.

    Continuity of history

    Asset history carried across the transfer, so the position keeps its full valuation and event record.

    Lifecycle of a continuation funds in Australia

    StageWorkRecord produced
    RationaleCase for continued ownership documented against the original hold thesis.Transaction rationale
    ValuationBasis set, third-party inputs recorded, conflicts disclosed.Valuation evidence pack
    ElectionInvestors elect to roll or exit within the notice period.Election register
    TransferAsset and its history move into the new vehicle.Continuous position record
    New holdFresh terms operate on the same underlying asset record.New vehicle reporting
    Governance and auditApprovals, conflicts, valuation policy and investor consents recorded as they happen rather than reconstructed at audit.Immutable decision log and evidence pack

    Stages describe the operating workflow. Statutory filings and local registration requirements are set by ASIC (Australian Securities and Investments Commission) and the fund's counsel.

    Often confused with

    Evergreen funds in Australia →

    An evergreen vehicle avoids the problem by never having a fixed end date. A continuation fund solves it after the fact, for a fund that does.

    Warehouse vehicles in Australia →

    A warehouse moves an asset into a fund before that fund exists. A continuation fund moves an asset out of a fund that is ending.

    Common questions

    What evidence do LPs expect in a continuation transaction?

    A documented rationale, a valuation basis with its third-party inputs, disclosed conflicts, recorded approvals and a clean record of every investor election, all timestamped in sequence.

    Does the asset lose its history in the transfer?

    It should not. Reuben AI keeps the underlying asset record continuous across the transfer, so valuations and events before the transaction stay attached to the position.

    Can partial rollovers be handled?

    Yes. An investor rolling part of their interest and taking liquidity on the rest is recorded as a single election producing two outcomes.

    Primary sources

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