Investing in real estate structures, family holdings, or utilizing repo operations has been governed by new rules since late June 2026. The Czech government approved an amendment to the regulation on the investment of investment funds, which clarifies how funds can handle loans, collateral, and specific instruments. For high-net-worth individuals and expats seeking returns beyond traditional stocks and bonds, this clarification of boundaries is good news, even though it brings another layer of regulatory complexity.
The new rules remove some illogical barriers for real estate funds while more strictly monitoring leverage and derivative operations. For the management of your family wealth, this means the need to verify whether the structures you use comply with the updated concentration and risk management limits.
Flexibility for Real Estate Structures and Family Holdings
One of the most significant changes brought by the amendment is the relaxation of rules for securing loans within 100% owned real estate structures. If a fund (or your holding) owns a real estate company 100%, loans between these entities no longer need to be mandatory secured. This significantly reduces the administrative burden and legal costs for internal project financing.
However, this pragmatic step has a safeguard: if the fund’s stake in the real estate company falls below 100%, you have exactly 6 months to either repay the loan or provide additional security. This deadline is critical – failure to comply can lead to sanctions from supervisors and unnecessary complications during a fund audit.
„Regulation should not punish efficient internal wealth management. Removing mandatory collateral for fully controlled subsidiaries returns logic to investment structures and reduces unnecessary bureaucratic costs.“
Caution Regarding Derivatives and Leverage
The amendment also focuses in detail on financial derivatives and repo operations. It refines the limits for instruments where clearing is not performed by a central counterparty (under the European EMIR regulation). In practice, this means that funds must be much more cautious when selecting counterparties and calculating total exposure.
💡 TIP: If your portfolio uses repo trades with Czech National Bank (CNB) bills, the amendment brings positive news – the acquisition limits will not apply to these highly liquid instruments within repo operations. This opens space for more efficient short-term cash management without fear of breaching regulatory limits.
At Aisa International, we do not approve individual transaction reports, but as part of our oversight, we ensure that your technical providers correctly implement these new parameters into their systems. Our role is strategic: we ensure your investment strategy does not fall “out of the game” simply because a derivative limit definition changed in the e-Legislature system.
How to Prepare for the New Investment Boundaries?
The changes are effective from June 25, 2026. For investors with complex assets, now is the time for preventative steps to ensure their investments remain within a secure and legal framework.
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Review of Intragroup Financing: If you use real estate funds with special purpose vehicles (SPVs), check the status of collateral for mutual loans.
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Leverage Analysis: Have your technical provider confirm that the calculation of leverage and derivative exposure complies with the new wording of Sections 22 and 25 of the regulation.
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Utilization of Repo Trades: Discuss with your advisor the possibility of optimizing cash flow through CNB bills, which now have a more relaxed regime.
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Strategic Audit with Aisa International: Together, we will look at whether your long-term financial plan still accounts for these regulatory changes and whether your oversight process covers new risks arising from the amendment.
Alternative investments require an active approach. While the government regulation amendment brings some simplification in technical details, the overall demand for wealth management compliance is growing. As your independent partner, we are here to filter out these complexities and leave you room for the investing itself.
FAQ: 5 Questions About the Investment Fund Amendment
1. Does this change affect me even if I am not a fund manager?
Yes, if you are an investor in qualified investor funds or use family holding structures. The changes affect the cost, risk, and financing options of your investments.
2. What is changing regarding investments in crypto-assets?
The amendment clarified that the 10% limit applies only to direct purchases of cryptocurrencies. Indirect investments (e.g., via certificates or derivatives) remain under the general risk management regime, giving funds more flexibility but requiring stricter oversight.
3. Why is a 100% stake in a real estate company important?
Because only with full ownership can you now utilize loans without the need for complex and expensive asset-backed security. Once your stake drops (e.g., by another investor joining), the rules immediately tighten.
4. How will the amendment affect the security of my investments?
Refining the rules for derivatives and clearing increases protection against counterparty default. The regulation aims to ensure that funds are not hiddenly over-leveraged through complex financial instruments.
5. Do I need to change my investment contract because of the amendment?
Probably not, but it is necessary for your investment intermediary or platform to perform a review of internal limits. Aisa International monitors this process as part of independent oversight of your portfolio.
