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Countries › Colombia › Guide › 10. Capital markets and finance › Investment funds and private equity in Colombia: collective investment funds (FIC), private equity funds (FCP), foreign funds, who may manage and sell them, and the pass through tax rule

Investment funds and private equity in Colombia: collective investment funds (FIC), private equity funds (FCP), foreign funds, who may manage and sell them, and the pass through tax rule

Last verified: 2026-10-27 · Status: Changing

Collective investment funds (FIC) and private equity funds (FCP) in Colombia can only be managed by stockbrokers, trust companies and investment management companies supervised by the SFC; an FIC must reach a minimum of 39,500 UVT within a year, and an FCP must put at least two thirds of its money into assets other than RNVE registered securities, have at least two investors and may hire a foreign professional manager. Foreign funds authorized by a supervisor that has an information sharing agreement with the SFC may be sold to professional and client investors, but only through a specialized distributor, and since August 2026 Colombian managers may also provide management services to foreign funds. Both FIC and FCP are not income taxpayers: income flows to investors with the same character it had in the fund.

USD figures use the TRM of COP 3,157.94 per US dollar valid on 27 October 2026, certified by the Superintendencia Financiera and published on the national open data portal (datos.gov.co). Amounts in UVT use the 2026 UVT of COP 52,374 (DIAN Resolución 000238 de 2025) and amounts in minimum wages use the 2026 monthly minimum wage of COP 1,750,905 (Decreto 1469 de 2025). Conversions are for orientation only.

Key facts

Minimum net assets of a collective investment fund (FIC)39500 UVTDecreto 2555 de 2010 art. 3.1.1.3.5, as of 2026-10-27 · in force
Term to reach the FIC minimum size (extendable once by 6 months)12 monthsDecreto 2555 de 2010 art. 3.1.1.3.5, as of 2026-10-27 · in force
Minimum share of FCP contributions in assets other than RNVE securities66.67 %Decreto 2555 de 2010 art. 3.3.2.1.1, as of 2026-10-27 · in force
Minimum number of investors in a private equity fund2 investorsDecreto 2555 de 2010 art. 3.3.2.2.6, as of 2026-10-27 · in force
Client investor cap on FCP commitments (of greater of income or net worth)20 %Decreto 2555 de 2010 art. 3.3.2.2.3, as of 2026-10-27 · in force
Notice to SFC before servicing a foreign fund15 business daysDecreto 2555 de 2010 art. 3.6.1.1.5 (Decreto 1013 de 2026), as of 2026-10-27 · in force
Income tax status of FIC and FCPNot taxpayers; income taxed in investors' hands textEstatuto Tributario art. 23-1, as of 2026-10-27 · in force

The rule

1. Collective investment funds (fondos de inversión colectiva, FIC) may only be managed by stock brokerage firms, trust companies and investment management companies, which for this purpose are called FIC managers. FICs are open or closed depending on how the duty to redeem units is structured, and are open unless their rules say otherwise. The rules of this Part do not apply to pension and severance funds, voluntary pension funds, mutual investment funds or foreign capital funds.Decreto 2555 de 2010, Part 3, as replaced by Decreto 1242 de 2013, Art. 3.1.1.1.1 and art. 3.1.1.2.2, 2010-07-15 official text · verified 2026-10-27
2. Every operating FIC must have a minimum net asset value set in its rules, which may not be lower than 39,500 UVT. The manager has one year from the start of operations to reach it, extendable once by the SFC for up to six months; if the minimum is not reached, the authorization is lost and the fund must be liquidated. The maximum stake of a single investor, directly or through an omnibus account, is set by the manager in the fund rules according to the fund's risks, size, liquidity, investment policy and investor profile, and does not apply in the first year of operation.
Cost to do it: The 2026 minimum fund size of 39,500 UVT is COP 2,068,773,000 (about US$655,102).
Example: A new fixed income FIC launched in March 2026 must reach COP 2,068,773,000 of assets by March 2027 or by September 2027 with the single extension. / That is roughly US$655,102 of investor money.Decreto 2555 de 2010, as amended by Decreto 1387 de 2022 art. 3 and Decreto 265 de 2024 art. 9, Art. 3.1.1.3.5 and art. 3.1.1.6.2, 2010-07-15 official text · verified 2026-10-27 · changed: Decreto 265 de 2024 art. 9 replaced the fixed per investor cap with a limit set in each fund's rules (see its transition regime in art. 26 of that decree).
3. Private equity funds (fondos de capital privado, FCP) are closed collective investment funds that must invest at least two thirds of investor contributions in assets or economic rights other than securities registered in the RNVE (indirect investments in RNVE securities do not count). The manager only has to redeem units at the end of the fund's term, though the rules may set earlier redemption dates no shorter than 30 calendar days. Assets financing public private partnership infrastructure under Ley 1508 de 2012 count toward the two thirds even if registered. FCPs may only be managed by stock brokerage firms, trust companies and investment management companies, and must have at least two investors.Decreto 2555 de 2010, Book 3 of Part 3, as replaced by Decreto 1984 de 2018, Art. 3.3.1.1.1, art. 3.3.2.1.1 and art. 3.3.2.2.6, 2010-07-15 official text · verified 2026-10-27
4. Investors may commit capital to an FCP through an unconditional promise to pay when capital is called; the manager must deliver the unit certificate within two business days after receiving each capital call. For client investors (non professional), the amount invested or committed in FCPs may not exceed 20 percent of the greater of their annual income or net worth, and the investor must declare it stays within that limit; the manager checks it when the commitment is signed. FCP units may be marketed by the professional manager, the managing company or the other authorized managers on its behalf.
Example: A client investor with annual income of COP 400 million and net worth of COP 1,500 million may commit up to COP 300 million to private equity funds. / That cap is about US$94,999 for that investor.Decreto 2555 de 2010, as amended by Decreto 1291 de 2020 art. 1 and art. 2 and Decreto 265 de 2024 art. 20, Art. 3.3.2.2.3 and art. 3.3.2.2.4, 2010-07-15 official text · verified 2026-10-27
5. The FCP manager may hire a professional manager (gestor profesional), a Colombian or foreign individual or company expert in the fund's target assets, who is responsible for investment decisions and answers up to slight negligence as a prudent and diligent expert; it may not subcontract the management. A foreign professional manager must appoint an individual with special power of attorney to represent it in Colombia. The managing company must report the hiring or removal immediately to the SFC and remains responsible for due diligence in selecting and supervising the manager. The professional manager may invest in the fund on the terms of its rules.
Example: A US private equity firm can run a Colombian FCP as gestor profesional, with a Colombian trust company as managing company and a local attorney in fact.Decreto 2555 de 2010, as replaced by Decreto 1984 de 2018, Art. 3.3.7.2.2 and art. 3.3.7.2.5, 2010-07-15 official text · verified 2026-10-27
6. Foreign investment funds are collective investment vehicles operating outside Colombia that were authorized by a supervisor that has information sharing and supervision agreements with the SFC and that also supervises the fund manager. To be recognized they must segregate assets, give periodic information to investors, have an independent professional custodian and not use leverage. Only professional investors and client investors may invest in them, and only if the same type of investor can buy them in the home market. Their distribution in Colombia may only be done through a specialized FIC distributor, which must tell investors that supervision is by the home supervisor.Decreto 2555 de 2010, Book 6 of Part 3, added by Decreto 1756 de 2017, Art. 3.6.1.1.1 to 3.6.1.1.4, 2010-07-15 official text · verified 2026-10-27
7. Colombian FIC managers may provide services related to the management of collective investment funds or equivalent vehicles set up abroad and authorized by a foreign supervisor. They must tell the SFC at least 15 business days before starting which foreign funds they will serve; supervision of the foreign fund stays with its home supervisor.Decreto 2555 de 2010, as amended by Decreto 1013 de 2026 art. 53, Art. 3.6.1.1.5, 2026-08-05 official text · verified 2026-10-27 · changed: Decreto 1013 de 5 August 2026 art. 53 added art. 3.6.1.1.5, allowing Colombian managers to service foreign funds.
8. Private equity funds and collective investment funds managed by an authorized entity are not income taxpayers. The manager's fee is taxable income for the manager and subject to withholding. The fund's income, net of fund expenses and the manager's fee, is distributed to investors with the same character and tax conditions as if they had received it directly. Recognition by investors is deferred until distribution only if the units trade on a Colombian exchange, or if no single beneficial owner, related group or family holds more than 50 percent and none controls distributions; funds created mainly to defer tax, for example to sell a specific asset, are taxed in the year the fund earns the income.
Example: A foreign investor in a Colombian real estate FCP that collects rent is taxed as if it had received the rent directly, when distributed if the fund meets the widely held tests.Estatuto Tributario art. 23-1, as amended by Ley 2010 de 2019 art. 68, Art. 23-1, 2019-12-27 official text · verified 2026-10-27
PointFICFCPRecognized foreign fund
ManagerStockbroker, trust company or investment management companySame, optionally with a Colombian or foreign professional managerForeign manager supervised at home
StructureOpen unless the rules say closedClosed; redemption at term or on set dates no shorter than 30 daysAs authorized at home; no leverage
Minimum size or investors39,500 UVT (COP 2,068,773,000) within a yearAt least two investorsNot set by these articles
Who may investPer fund rulesProfessional investors; client investors up to 20% of income or net worthProfessional and client investors
DistributionManager or distributorsManager, professional manager or other authorized managersOnly through a specialized distributor
Income taxNot a taxpayerNot a taxpayerNot covered by art. 23-1

Fund vehicles compared (Decreto 2555 de 2010 Part 3; Estatuto Tributario art. 23-1)

Worked example

  • A US manager wants Colombian pension funds and family offices in a new Andean infrastructure strategy. Option one: a Colombian FCP managed by a local trust company with the US firm as gestor profesional, investing at least two thirds outside RNVE securities, with income taxed only in investors' hands (Decreto 2555 de 2010 art. 3.3.2.1.1 and 3.3.7.2.2; ET art. 23-1). Option two: sell units of its US or Luxembourg fund through a Colombian specialized distributor if the home supervisor has an information sharing agreement with the SFC and the fund uses no leverage (art. 3.6.1.1.1 to 3.6.1.1.4).
  • A Colombian client investor with net worth of COP 2,000 million can commit at most COP 400 million (about US$126,665) to private equity funds if that exceeds 20 percent of annual income (art. 3.3.2.2.3).

Step by step

  1. 1. Choose the vehicle: FIC for liquid or listed strategies, FCP for private assets, or a recognized foreign fund for an existing offshore product.
  2. 2. Select a licensed Colombian managing company (stockbroker, trust company or investment management company) and, for an FCP, decide whether to hire a professional manager.
  3. 3. Draft the fund rules, including per investor limits, redemption terms and conflicts, and obtain SFC authorization.
  4. 4. For client investors in FCPs, collect the 20 percent declaration at commitment (art. 3.3.2.2.3).
  5. 5. Check the art. 23-1 deferral tests (exchange traded units or no beneficial owner above 50 percent) before closing the investor base.
  6. 6. For an FIC, track the 39,500 UVT minimum during the first year.

Common traps

  • Marketing a foreign fund directly to Colombian residents instead of through a specialized distributor (art. 3.6.1.1.4) and without a representative office (see the cross border services page).
  • Building an FCP around a single investor or family above 50 percent: income is then recognized as the fund earns it, not on distribution (ET art. 23-1).
  • Missing the one year ramp up: an FIC below 39,500 UVT after the term loses its authorization and must liquidate (art. 3.1.1.3.5).
  • Letting the professional manager subcontract portfolio decisions, which art. 3.3.7.2.2 forbids.

Sources

Related pages

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