How to Launch a Private Credit Fund in Australia: A Step-by-Step Guide

July 29, 2026

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7 min to read

To launch a private credit fund in Australia, you set up a fund vehicle — most often a unit trust run as a managed investment scheme — put the right licensing in place (AFSL coverage to raise capital, plus a credit licence if you lend to consumers), decide whether you will accept wholesale or retail investors, prepare your trust and offer documents, and stand up fund operations such as registry, administration, valuation and compliance before any money comes in. The process is regulated and document-heavy, but for most managers it is a sequenced project rather than a barrier.

Here is a simple walk-through of each step, the licensing point that catches out first-time private credit managers, and where the rules are heading in 2026.

What is a private credit fund, and why Australia is watching

A private credit fund pools investor money and lends it out, earning a return from interest and fees rather than from buying and selling assets. The loans sit outside the banking system: direct lending to companies, property and construction finance, asset-backed lending and similar private debt. Investors gain exposure to those loans by holding units in the fund.

The sector has grown fast. EY estimates the Australian private credit market reached around $213 billion at the end of 2024 — more than 500% above its 2015 level of roughly $35 billion, a figure carried in ASIC's 2025 capital-markets reporting. That growth has drawn the regulator's attention. Between October 2024 and August 2025, ASIC reviewed 28 private credit funds across listed, unlisted, retail and wholesale categories, and has since set out clearer expectations on valuations, liquidity, fee disclosure and conflicts of interest. Anyone planning a new fund should build to those expectations from day one.

Step 1 — Choose the right fund structure

In Australia, most private credit funds are set up as a unit trust that operates as a managed investment scheme (MIS). The trust holds the loans, investors hold units, and a trustee sits over the assets. Two early choices shape everything that follows:

Open-ended or closed-ended. Private loans are illiquid, so the fund's redemption terms must match the assets behind them. Many credit funds use a closed-ended or limited-liquidity design with defined redemption windows rather than daily withdrawals. A liquidity mismatch is one of ASIC's stated concerns.
Single trust or layered. Smaller funds often run as a single trust. Larger or warehouse-style operations may use feeder trusts, contributory style funds, a warehouse facility or a fund-of-funds arrangement. Each added layer raises governance and related-party questions you will need to answer for investors.

Your loan strategy shapes the structure: who you lend to, where those loans sit in the capital stack, how you price and secure them, and how you handle problem loans. Settling this first makes the licensing and documents that follow far simpler.

Step 2 — Get the licensing right (where private credit differs)

This is the part that surprises managers coming from equities or property. A private credit fund sits under two separate licensing regimes, and clearing one does not clear the other.

Raising the money — your AFSL. Operating an MIS is a financial service. The fund needs Australian Financial Services Licence (AFSL) coverage with the right authorisations — for dealing in scheme interests, for custody where the trustee holds assets, and for advice if you give it. You can hold your own AFSL or operate as a corporate authorised representative (CAR) under another licensee. The CAR route is common for first-time managers because it cuts the time and cost of standing up a licence. For the details, see FundBase Group's guide on what an AFSL is and whether you need one.

Lending the money — your credit licence. Here is the catch. If your fund lends to a natural person for a purpose covered by the National Consumer Credit Protection Act — personal, domestic or household credit, or residential investment property — that is a “credit activity,” and it generally needs an Australian Credit Licence (ACL). A wholesale AFSL gives you no shield against this. The status of your investors has nothing to do with the status of your borrowers.

Seek advice on both regimes before you write a single loan. Fixing a licensing gap after launch is slow and costly.

Step 3 — Wholesale or retail investors?

Who you let into the fund changes the cost, the paperwork and the time to launch.

Wholesale only. Most emerging managers start here. A wholesale fund typically uses an Information Memorandum rather than a full Product Disclosure Statement, runs as an unregistered MIS, and carries a lighter disclosure load. You still need AFSL coverage and compliance processes to confirm each investor qualifies as wholesale.
Retail. Opening the fund to retail investors raises the bar: a registered MIS, a responsible entity holding the right AFSL authorisations, a Product Disclosure Statement, a Target Market Determination, a compliance plan and an external audit of that plan. The protections are heavier, and so are the costs.

A common path is to launch wholesale, prove the strategy, then add a retail structure once systems and a track record are in place. FundBase Group's breakdown of wholesale vs retail investors in Australia goes deeper on the trade-offs.

Step 4 — Documents and what ASIC now expects

Your governing and offer documents set out the rights and obligations of everyone involved. At a minimum, you will prepare:

a trust deed or constitution covering unit issue and redemption, valuation and distributions;
an offer document — an Information Memorandum for wholesale, or a Product Disclosure Statement for retail;
an investment management agreement delegating loan decisions from the trustee to the manager; and
a CAR agreement, if you operate under another party's AFSL.

Write these to meet where the regulator is heading, not just today's minimum. ASIC's recent private credit work points to four areas a new fund should get right in its documents and its operations: how loans are valued and how often; how liquidity and redemptions are managed; how fees and margins — including borrower-paid fees — are disclosed in full, and how related-party and conflict situations are handled.

Step 5 — Build operations before capital arrives

A fund has to run in line with its documents and the law from the first dollar. Whether you handle these in-house or outsource them, the work includes:

investor onboarding with KYC/KYB and AML/CTF checks;
maintaining the unit registry and investor records;
NAV and unit pricing, backed by a documented valuation policy;
loan servicing, monitoring and arrears management;
investor and tax reporting, plus audit coordination; and
ongoing compliance monitoring and governance.

Responsibility for all of this stays with the manager and trustee even when providers do the work, so oversight and record-keeping matter. Investors will look closely at the quality of your operations and reporting before they commit. Many managers weigh up in-house vs outsourced fund administration at this stage, since back-office strength is now an expectation rather than a nice-to-have.

How long does it take, and what does it cost?

There is no single answer. A wholesale fund using an established AFSL holder and a single trust can be ready in a matter of weeks. A retail fund that needs its own registered scheme, responsible entity and Product Disclosure Statement takes longer and costs more. The variables are your investor type, your licensing path, the structure's complexity, and how ready your documents and operations are. Building each piece in the right order — strategy, structure, licensing, documents, operations — is what keeps the timeline and the budget under control.

A faster, more disciplined path to launch

Most of the delay in launching a private credit fund comes from stitching together separate providers — a trustee here, a licensee there, an administrator and a registry somewhere else — and getting them to work as one.

FundBase Group brings those pieces under a single partner. Through Fund-in-a-Box and its Fund Services, one team handles fund formation and documents, AFSL coverage under a CAR arrangement, trustee and responsible entity services, investor onboarding and registry, fund administration and accounting, and ongoing compliance and reporting — supported by a proprietary technology platform with investor and manager portals. The payoff is concrete: fewer handovers between providers, one set of records, less duplicated cost, and a launch measured in weeks rather than months, without cutting corners on compliance or governance.

The team's background sits in financial services law and AFSL incubation, so the operational and regulatory detail behind a credit fund is familiar ground.

If you are planning a private credit fund, contact FundBase Group to talk through your structure, investor base, timeline and the licensing path that fits.

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