California's Fair Investment Practices by Venture Capital Companies Law Applicability Decision Tree and Compliance Checklist

California’s Fair Investment Practices by Venture Capital Companies Law (FIPVCC) imposes new registration and reporting obligations on certain venture capital companies (covered entities) with a nexus to California. The FIPVCC is administered by the California Department of Financial Protection and Innovation (DFPI) and is intended to increase transparency regarding the demographics of founding teams of businesses in which covered entities invest. The FIPVCC is broad in its reach, thus even clients that have no California offices or presence may still be subject to its registration and reporting requirements.

At a high level, the FIPVCC requires a covered entity to register with the DFPI and to submit annual reports containing anonymized, aggregated demographic information regarding founding team members of portfolio companies in which the covered entity made venture capital investments during the preceding calendar year. The obligation to register begins on March 1, 2026, and the demographic report is due April 1, 2026.

Sidley has prepared two client resources to support FIPVCC assessments and compliance: (1) an applicability decision tree to help clients evaluate whether any fund/trading vehicle is a covered entity and (2) a high-level compliance checklist for covered entities detailing the registration, data collection, reporting, and recordkeeping requirements. These materials are provided for informational purposes only and are not legal advice.

Sidley’s Private Funds team is available to assist with implementation planning and ongoing compliance with the FIPVCC.