CNB Reporting for § 15 ZISIF

What is CNB Reporting (via SDAT, ROFOS 36, ROFOS 37, and DOFOS 15)?

It refers to a statutory information obligation set out in Article 110(1) of EU Regulation No. 231/2013, § 462, 463(2)(b), and 475 of the Czech Act on Investment Companies and Investment Funds, and further specified in § 6 of Decree No. 267/2020 Coll. This pertains to the reporting obligation of entities registered under § 15 of ZISIF (i.e., alternative investment funds).

In simpler terms, all alternative investment funds are required by law to report certain specific information to the Czech National Bank in a prescribed manner regarding their investment activities.

What is reported to the Czech National Bank via ROFOS 36 and 37?

Although alternative investment funds are not supervised or monitored by the CNB, they are still legally required to fulfil their reporting obligations. The reporting methods and requirements must be monitored continuously. We are happy to assist you in setting up and completing your fund’s reporting.

The report must include, in particular, information on:

• the composition of the fund’s assets, broken down by types of investable items;
• the number of investors in the fund;
• the most important and significant investment instruments the fund trades with;
• the most significant exposures of the fund.

In relation to investors, the fund must state whether the investor’s registered address or residence is within the Czech Republic or abroad. Any changes to this information must also be reported.

No assets under management? This too must be reported (in a specific format).

Alternative Investment Fund reporting and ROFOS 36 and ROFOS 37 Statements

ROFOS 36 and 37 are structured reports that an alternative investment fund must submit to the CNB via the SDAT system. We’re happy to help you with completing these forms.

Many entities struggle with ROFOS 36 and 37 because they are not user-friendly or intuitive.

What is reported to the Czech National Bank via the DOFOS 15 Report?

Starting in 2025, the CNB has introduced a new report, DOFOS 15, designed specifically for managers under § 15(1) ZISIF (i.e., venture capital entities).

This report serves to notify the CNB of the total number of investors, in connection with the new obligation to submit an auditor’s report under § 15(6) ZISIF (if the fund exceeds the limit of 20 investors).

The DOFOS 15 report must reflect the status as of December 31st of each year, and the deadline for submission is June 30th of the following year.

Is an alternative investment fund obliged to submit regular reporting to the CNB via SDAT and ROFOS/DOFOS??

Yes, an alternative investment fund must submit regular annual reports to the CNB, no later than January 31st of the following year.

How is reporting submitted to the CNB?

All reporting must be submitted electronically via the SDAT system, which is the CNB’s dedicated application for fulfilling reporting obligations.

How often must reports be submitted?

Alternative investment funds must submit reports to the CNB once per year, always by the end of January of the following year for the period being reported.

The DOFOS 15 report must reflect data as of December 31st each year, with a submission deadline of June 30th of the following year.

What are the penalties for failing to report to the CNB?

Failure to meet the reporting obligation can result in a fine of up to CZK 150,000,000 under § 616(5) of the Act on Investment Companies and Investment Funds ("ZISIF"). In practice, fines usually range between CZK 50,000 – 70,000.

In the event of neglect of the reporting obligation and non-communication with the Czech National Bank, the alternative fund may also be deleted pursuant to § 506(1)(f) ZISIF from the list of persons carrying out asset management comparable to asset management pursuant to § 15(1) ZISIF maintained by the Czech National Bank pursuant to § 596(f) of the same Act.

Need help with CNB reporting and ROFOS/DOFOS filings?

Don’t hesitate to contact us using the inquiry form below.

Where to next?

• What is an alternative investment fund?
• Obligations of the fund manager
• Turnkey establishment of an alternative fund
• AML obligations
• Preparing a KID under the PRIIPs Regulation
• Investment agreement
• Investment strategy
• News