Carlos Lopez By Carlos Lopez

Crypto & Fintech · European Union

Crowdfunding Campaigns Under the EU's ECSP Regulation: Key Investment Information Sheet Requirements

Cross €5 million raised in any rolling 12-month period, and your campaign doesn't just get more scrutiny — it exits the ECSP framework entirely and needs a full securities prospectus instead.

One License Instead of a National Patchwork

Before Regulation (EU) 2020/1503 — the European Crowdfunding Service Providers Regulation (ECSPR) — a crowdfunding platform wanting to operate across five member states needed five separate national authorizations. ECSPR, fully applicable since 10 November 2021, replaced that patchwork with a single EU-wide authorization: one license from a home regulator, passportable across the EEA.

The €5 Million Threshold

ECSPR sets a maximum funding threshold of €5 million per project, calculated as the total raised across any rolling 12-month period, combined across all ECSP platforms a project owner might use simultaneously — not just a single platform in isolation. Crossing this threshold takes the offer entirely outside ECSPR's scope; at that point, the existing securities framework applies instead — specifically the EU Prospectus Regulation (Regulation (EU) 2017/1129) and the corresponding national implementing legislation, which impose substantially heavier disclosure obligations than ECSPR's own requirements.

There has been industry discussion about raising this threshold — a 2026 proposal argued for increasing it to €12 million to align with a separate change under the EU Listing Act — but as of this writing, that proposal has not been adopted, and €5 million remains the operative ECSPR threshold. Confirm the current figure directly with ESMA or your national regulator before relying on any higher number you might encounter elsewhere.

The Key Investment Information Sheet (KIIS)

For every offer within the ECSPR framework, the project owner must prepare a Key Investment Information Sheet (KIIS) in the standardized format set out in Annex I of the Regulation — this is what replaces a full prospectus for offers under the €5 million threshold, giving retail investors clear risk disclosure without the cost and complexity of a full securities prospectus. Platforms are also required to run entry knowledge tests for non-sophisticated investors and apply a mandatory reflection period before an investment commitment becomes binding.

A campaign whose KIIS doesn't conform to the required standardized format is a real, concrete compliance failure — not a stylistic preference — and this is one of the more common reasons ECSP platforms suspend or reject an otherwise fundable campaign.

What This Means for You

If you're raising capital via EU crowdfunding, track your cumulative total across all platforms you're using — not just the platform in front of you — against the €5 million ceiling, since exceeding it (even inadvertently, by running simultaneous campaigns) pulls you into full prospectus territory. Work directly from the Annex I KIIS template rather than adapting a generic pitch deck into what you assume the format should look like.

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