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Equity Crowdfunding NZ

Equity crowdfunding lets ordinary investors buy shares in early stage companies through a licensed online platform. The pitch is access: the sort of opportunity that once went only to wealthy investors, open to anyone with a few hundred dollars.

The access is real. What is less often stated is what was removed to make it possible, because the regime works by switching off the disclosure obligations that apply to ordinary public offers.

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The three things to remember

An issuer can raise up to $2 million in twelve months this way. There is no product disclosure statement. And there is usually no way to sell, at any price.

What the exemption does

A company making a public offer of shares in New Zealand normally has to produce a product disclosure statement, a prescribed document with prescribed content, and register it. That is expensive, which is why small companies historically could not raise money from the public at all.

The crowdfunding regime removes that requirement for offers made through a licensed intermediary, up to $2 million in any twelve month period. The platform is licensed and has obligations. The company largely does not, in disclosure terms.

Ordinary public offer Equity crowdfunding offer
Registered product disclosure statement required Not required
Prescribed content and format Whatever the platform requires
Financial statements to a set standard Often limited and sometimes unaudited
Liability attaches to the disclosure document Far narrower
Usually a liquid market afterwards Usually no market at all
The pitch page is marketing, not disclosure

What you are reading on a crowdfunding page was written to persuade you, and it is not a document with the legal weight of a product disclosure statement behind it. That does not make it dishonest. It means the diligence a disclosure regime would ordinarily do on your behalf has not been done by anyone, and if you do not do it, it is simply not done.

The illiquidity, which is the underestimated part

Listed shares can be sold on any trading day at whatever the market offers. Crowdfunded shares in a private company generally cannot be sold at all. There is no exchange, usually no secondary market of any kind, and often constitutional restrictions on transfer requiring board approval.

So the realistic assumption is that money committed is inaccessible until one of three things happens: the company is sold, it lists, or it fails. Those are the exits, and the first two are rare and the third is common.

Assume no dividends, because early stage companies reinvest rather than distribute.
Assume no sale, because there is no market to sell into.
Assume a horizon of many years, if an exit comes at all.
Assume the most likely single outcome is zero, because for early stage companies it is.
If that set of assumptions is unacceptable, the investment is unsuitable regardless of the pitch.

Dilution

A company that raises money once will usually raise again, and each subsequent round issues new shares. Your percentage falls unless you can put in more, and small investors generally cannot and often have no pre-emptive right to.

Later rounds may also carry terms your shares do not have: liquidation preferences that pay those investors first on a sale, or anti-dilution protections. It is entirely possible to own shares in a company that sells for a substantial sum and to receive very little, because the money goes to preferred holders ahead of you.

Reading an offer properly

What is the valuation, and on what basis? Early stage valuations are negotiated, not calculated.
What are the financials, and are they audited or management-prepared?
Who else has invested, at what price, and on what terms compared with yours?
What class of share am I buying, and does it carry votes and pre-emptive rights?
What is the money for, and how long does it last at the current burn rate?
Who is the team, and what have they done before this?
The third and fourth questions are the ones least often asked and most often decisive.
Valuation is where enthusiasm does the most damage

A good business bought at a bad price is a bad investment. Early stage valuations are the outcome of a negotiation rather than a calculation, and a crowd of small investors has no negotiating position at all, so the price is simply presented. Comparing the implied valuation against actual revenue is a sobering exercise and takes about five minutes.

What the platform's licence covers

A licensed intermediary must meet its own obligations, including some checks on issuers and fair dealing requirements. That is worth something, and it is worth understanding precisely: the licence covers the platform's conduct. It is not an endorsement of any company on it, not a view on the valuation, and not a suggestion that the business will succeed.

A sensible way to participate

Treat it as money you can lose entirely, because that is the most likely single outcome.
Size it as a small fraction of your investments, not as a core holding.
Spread across several companies if you do this at all, since returns are concentrated in rare winners.
Expect a decade, not a few years, and expect no income meanwhile.
Never invest because you like the product, which is the most common reason people do.
The last line accounts for a great deal of the money lost here.

That final point deserves elaborating. Crowdfunding campaigns are frequently for consumer businesses with appealing products, and enthusiasm for a product is not analysis of a business. Plenty of companies make something excellent and never make money, and as a shareholder you are buying the second thing rather than the first.

What this guide does not cover

Individual offers, platforms and their terms vary widely and nothing here describes any particular one. Wholesale investor exemptions, convertible instruments, SAFE arrangements and the tax treatment of losses on shares each require specific advice. This is general information rather than financial advice, and equity crowdfunding is high risk capital that should only be committed by people who could lose it entirely without it changing their circumstances.

Related guides and tools

Test Your Knowledge

Ten questions on crowdfunded shares, disclosure and liquidity.

1. How much can an issuer raise this way in twelve months?
Up to $500,000
Up to $2 million
Up to $10 million
There is no upper limit
2. What does the crowdfunding exemption remove?
The requirement for a product disclosure statement
The need for the company to keep accounts
The investor's right to vote at meetings
The platform's obligation to be licensed
3. What is a crowdfunding pitch page, legally?
A registered offer document with full liability
An audited statement of the company's position
Marketing, without the weight of a disclosure document
A regulated prospectus reviewed by the FMA
4. How do you sell crowdfunded shares?
On the NZX, at the prevailing market price
Back to the platform, at the issue price
To other investors, through the platform monthly
Generally you cannot, as there is no market
5. What is the most likely single outcome of an early stage investment?
A modest positive return
Zero
A return matching the sharemarket
A return of capital with no gain
6. What is dilution?
The company reducing its share price
Your percentage falling as new shares are issued
The platform taking a fee from your holding
The share value falling with the market
7. Why might you receive little from a successful sale?
Later investors may hold liquidation preferences
Crowdfunded shares expire after ten years
The platform takes half of any gain
Private company sales are not distributed
8. How are early stage valuations arrived at?
Set by an independent registered valuer
Calculated from audited earnings multiples
Negotiated, not calculated
Determined by the Financial Markets Authority
9. What does the platform's licence cover?
The quality of every business listed
A guarantee of the valuations shown
The platform's own conduct, not the companies on it
Compensation if an investment fails
10. What is the most common poor reason to invest?
Believing the valuation is reasonable
Knowing someone on the founding team
Wanting exposure to early stage companies
Liking the product the company makes

Sources: the Financial Markets Conduct Act 2013 and its regulations, under which licensed crowdfunding intermediaries may facilitate offers of up to $2 million in any twelve month period without a product disclosure statement. Platform terms and issuer disclosure vary widely. This is general information rather than financial advice, and equity crowdfunding is high risk capital that should only be committed by people who can lose it entirely.

Work it out: Co-Ownership Equity Share Calculator