Am I a wholesale investor (and can I invest with Reach Alts)?

Reach Alts’ private market funds are generally available to wholesale investors (often referred to as “sophisticated investors” in this context). Wholesale status matters because the law allows different disclosure and investor-protection settings for wholesale vs retail investors.

This page is general information only and not legal, tax or financial advice. If you’re unsure, please speak with your accountant (or adviser).

Last updated: 2 January 2026

Quick answer: most investors qualify with a qualified accountant’s certificate (“708 certificate”)

For many investors, the simplest route is a certificate from a qualified accountant confirming you meet either:

• Net assets of at least $2.5 million, or

• Gross income of at least $250,000 per year in each of the last two financial years.

The certificate generally needs to be issued within the previous 6 months to be relied on. Reach Alts provides a template certificate your accountant can complete.

Otherwise, you do not need a certificate if investing $500,000 or more in an offering.

Who can issue the certificate?

ASIC explains the “qualified accountant” requirements and references the relevant instrument and eligibility criteria for accountants.

Step 1: Identify the investor (individual, company, trust, SMSF) and “who the certificate should cover”

A good starting point is: the certificate should generally match the legal person/entity that is investing (i.e., the party named on the application and making the investment).

1) Individuals (investing in your own name)

If you invest personally, the certificate is usually issued in your name.

Controlled entities may be relevant: The Corporations Act uses a concept of control that can matter in some structures. Control is about the capacity to determine the outcome of decisions about an entity’s financial and operating policies, looking at practical influence and patterns of behaviour, not just formal rights. (Your accountant will apply this to your structure; we can’t tell you what does or doesn’t count.)

2) Two people investing together (joint investors)

If the investment is in two names (e.g., “Jane Smith and John Smith”), many providers take a conservative approach and will expect the certificate to clearly cover each named investor (either two certificates, or one certificate that names both and confirms each meets the test).

Why the caution? Because the legal tests focus on the person to whom the offer is made and where there is more than one investor, it becomes important that each investor is appropriately classified.

3) Companies (e.g., “ABC Pty Ltd”)

If a company is investing, there are two common ways this is handled in practice:

• The certificate is issued for the company (based on the company’s financial position), or

• The certificate is issued with reference to an individual who controls the company (depending on how the offer is structured and documented).

What “control” means (plain English): control is the capacity to “call the shots” on financial/operating policy outcomes, including via practical influence (not just shareholding percentage).

Because “control” can depend on constitutions, shareholder agreements, voting rights, and how decisions are actually made, accountants often ask for structure details before issuing a certificate.

4) Trusts (family trusts, unit trusts)

A trust is often the area where investors get stuck—because a trust generally acts through its trustee (individual trustee(s) or a corporate trustee).

In practical onboarding, you’ll often see the investor named as either:

• [Trustee name] as trustee for [Trust name], or

• [Individual trustees] as trustees for [Trust name].

If there are multiple individual trustees: many providers treat this similarly to a “joint investor” scenario and will want comfort that the wholesale basis appropriately covers each trustee (or that the certificate clearly names and covers each trustee).

If there is a corporate trustee: the certificate will typically be issued in the name of the corporate trustee (as trustee). Some providers may still ask questions about who sits behind the trustee because of how wholesale classification can be assessed in disputes (see SMSF note below).

SMSFs: a practical note

An SMSF is effectively a trust structure, so the investor is usually the trustee(s) (individual trustees or a corporate trustee acting as trustee for the fund).

Can an SMSF provide an accountant’s certificate?

In many investment contexts, SMSF trustees do provide accountant’s certificates and are treated as wholesale/sophisticated investors for those offers.

Why are some providers more cautious with SMSFs?

AFCA has recently reiterated that when a financial service/advice relates to a superannuation product, an SMSF trustee must be treated as a retail client unless the SMSF has $10 million or more in assets. In that setting, AFCA says the usual “assets/income” wholesale tests (like $2.5m / $250k) don’t apply.

What this means in practice: an SMSF can still invest and may still provide an accountant’s certificate, but some providers may take a more conservative approach with SMSFs (e.g., requesting extra confirmation or applying retail-style disclosures/processes) because SMSF trustees under $10m may still be treated as retail clients for complaint purposes.

What this means for you: an SMSF can still invest and can still obtain an accountant’s certificate, but you may find some providers ask for additional documentation.

Step 2: What the “asset test” and “income test” usually refer to

• Net assets is generally understood as assets minus liabilities at a point in time.

• Gross income is generally understood as income before tax, assessed per financial year.

Exactly what’s included can depend on your circumstances and structure—your accountant will apply their professional judgement and the requirements relevant to the certificate.

Step 3: What to do next (simple checklist)

1. Confirm who is investing (you personally, joint, company, trustee of a trust/SMSF).

2. Ask your accountant for a Qualified Accountant’s Certificate confirming the $2.5m net assets or $250k income (x2 years) threshold.

3. Ensure it’s current (within 6 months).

4. Provide it during your Reach Alts onboarding / subscription process.

Other ways investors may qualify (briefly)

Depending on the product and circumstances, there are other legal pathways that may result in wholesale treatment (for example, higher minimum investment tests, professional investor categories, or experience-based pathways that involve specific written statements and acknowledgements). These are more situation-specific, if you think one might apply, your accountant/adviser can guide you.

Benefits and trade-offs of being a wholesale investor

Potential benefits

• Access to a wider range of investment opportunities (including many private market funds).

• Often a more streamlined process.

Important trade-offs

• Wholesale investors can receive fewer retail protections and disclosures (depending on the product and pathway used).

FAQs (designed for quick answers)

What is a “708 certificate”?

It’s shorthand for a qualified accountant’s certificate commonly used for the “sophisticated investor” pathway under the Corporations Act, based on the $2.5m net assets or $250k income (x2 years) thresholds.

Does the certificate have to be recent?

Yes—this certificate is generally relied on only if it was issued no more than 6 months before the offer/investment.

I’m investing through a trust—who needs to be named?

Usually the trustee is named as the investor (e.g., “ABC Pty Ltd as trustee for the Smith Family Trust”). Where there are multiple trustees, providers may ask for the certificate to clearly cover the relevant parties (often each trustee), to ensure the investor is properly classified.

I’m investing through a company—what does “control” mean?

Under the Corporations Act, control is the capacity to determine the outcome of decisions about an entity’s financial and operating policies, taking into account practical influence and patterns of behaviour.

Can my SMSF invest using an accountant’s certificate?

Often, yes. SMSF trustees commonly provide accountant’s certificates for relevant investment offers.
However, some providers apply extra caution because AFCA’s approach in complaints has increased scrutiny.

If I’m unsure, what’s the fastest way to resolve it?

Ask your accountant to confirm (1) the correct investing entity name and (2) the appropriate certificate wording for your structure (individual / joint / company / trustee / SMSF).