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Potential Harm to Funding Startups in Australia: Lessons from the UK's Experience with Raising Wholesale Investor Thresholds

Potential Harm to Funding Startups in Australia: Lessons from the UK
Potential Harm to Funding Startups in Australia: Lessons from the UK

As Australia contemplates changes to its wholesale investor thresholds, the startup community braces for potential disruptions. The proposed changes involve raising the asset threshold from $2.5 million to $4.5 million and the income threshold from $250,000 to $450,000.

While these adjustments aim to align investor qualifications with current economic conditions and enhance consumer protection, they risk significantly limiting access to capital for early-stage companies—a scenario that the UK has already faced with similar reforms.

The UK's Experience: A Cautionary Tale

The UK government's recent adjustments to high-net-worth investor thresholds have faced considerable backlash, particularly from the startup sector. The changes included raising the income and net asset thresholds for qualifying as a sophisticated investor. This move, intended to protect investors, inadvertently created funding difficulties for startups by shrinking the pool of eligible investors.

Critics argue that the higher thresholds made it harder for early-stage companies to attract investment, as the number of individuals meeting the new criteria dropped significantly. Startups, which typically rely on a diverse range of investors, found themselves competing for a smaller pool of capital, leading to reduced funding opportunities and potentially stifling innovation and growth in the sector.

The UK government has reversed the order effective March 27, 2024.

Potential Impact on Australian Startups

Australia's startup ecosystem could face similar challenges if the proposed changes to the wholesale investor thresholds are implemented. The increased thresholds could drastically reduce the number of investors eligible to support early-stage ventures, leading to a significant contraction in available funding. This reduction in capital flow could have several adverse effects:

  • Limited Access to Capital: Startups, particularly those in the early stages, rely heavily on funding from high-net-worth individuals who meet the current wholesale investor criteria. By raising the thresholds, the government would reduce the number of eligible investors, thereby limiting the pool of potential funding sources.

  • Stifled Innovation: With fewer investors able to participate in funding rounds, startups may struggle to secure the necessary capital to bring innovative ideas to market. This could slow down the pace of innovation and reduce Australia's competitiveness in the global tech landscape.

  • Increased Dependency on Institutional Investors: As individual investor participation declines, startups may become more reliant on institutional investors, such as venture capital funds. While this is not inherently negative, it could lead to more stringent terms and conditions for startups, potentially limiting their operational flexibility and creative freedom.   The funding pool for many Australian venture capital funds will also reduce if the thresholds are bought in.

Stakeholder Concerns and Alternative Proposals

Stakeholders across the startup and investment communities have voiced opposition to the proposed changes. Early-stage investors, industry bodies, and tech entrepreneurs argue that the increased thresholds could disproportionately affect small investors and startups, creating barriers to entry and stifling growth.

One of the primary concerns is that raising the thresholds would be a blunt instrument that fails to address the underlying issues of investor protection and financial literacy. Instead, critics suggest more nuanced approaches, such as:

  • Investor Education Programs: Implementing comprehensive investor education programs to ensure that investors are well-informed about the risks and opportunities associated with startup investments.

  • Investor Certifications: Introducing certification processes for investors, allowing them to qualify based on their knowledge and experience rather than solely on their financial standing.

  • Maintaining Lower Thresholds for Smaller Investments: Keeping the current thresholds for investments up to a certain amount, such as $200,000, to ensure that smaller investors can continue to participate in funding rounds without facing undue restrictions.

The Parliamentary Inquiry and Future Outlook

The Parliamentary Joint Committee on Corporations and Financial Services is currently conducting an inquiry into the wholesale investor and client tests. The inquiry aims to review the existing thresholds, compare them with international standards, and evaluate the potential impacts of any proposed changes. The committee is expected to report its findings by the end of 2024, with public submissions being accepted until mid-May 2024.

This inquiry presents an opportunity for stakeholders to voice their concerns and propose alternatives that balance investor protection with market accessibility. The final outcome will likely shape the future landscape of startup funding in Australia, determining whether the country can maintain a vibrant and innovative startup ecosystem.


Australia stands at a crossroads as it considers raising the thresholds for wholesale investors. The UK's experience serves as a stark reminder of the potential consequences of such changes. By learning from these international examples and considering alternative approaches, Australia can create a regulatory environment that protects investors while supporting the growth and innovation of its startups. The outcome of the current parliamentary inquiry will be crucial in striking this balance, ensuring that the country's startup sector continues to thrive in a competitive global market.


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