Rules and limits
ECSPR explained: how EU crowdfunding works across borders
ECSPR is the EU regulation that lets one crowdfunding platform, authorised in one member state, offer investments across the EU on a single set of rules, for raises of up to €5m in 12 months. As of 4 Nov 2026 it gives a platform a passport and gives investors the same protections everywhere, but it leaves marketing rules, language and tax largely with each country, and most money still stays at home.
Not investment advice. Early-stage investing is high-risk and illiquid; you may lose all the capital you invest.
Some points here have not been confirmed against a primary source. Each is marked “Not yet verified”, and this page stays out of search until they are.
| Point | What the rule says | Source |
|---|---|---|
| Most a company can raise | €5m in 12 months, counted across platforms and certain exempt public offers | Art. 1(2)(c) (opens in a new tab), ESMA Q&A 2437 (opens in a new tab) |
| Who may run a platform | A legal person established in the EU and authorised by its national regulator | Art. 3(1), Art. 12 (opens in a new tab) |
| Passport | Notify the home regulator; start once it confirms the host has been told, or at the latest 15 calendar days after submitting | Art. 18 (opens in a new tab) |
| Limit on what you invest | None fixed; extra steps above the higher of €1,000 or 5% of net worth in one offer | Art. 21(7) (opens in a new tab) |
| Time to change your mind | Four calendar days, if non-sophisticated | Art. 22 (opens in a new tab) |
| Disclosure | A key investment information sheet of at most six A4 sides | Art. 23 (opens in a new tab) |
| Compensation | Not covered by deposit guarantee or investor compensation schemes | Art. 23(6) (opens in a new tab) |
| Live raises we track | 20 | Our ECSPR list |
What is ECSPR?
It is short for the European Crowdfunding Service Providers Regulation, Regulation (EU) 2020/1503 (opens in a new tab), which has applied since 10 November 2021. Platforms already working under national law had until 10 November 2023 (opens in a new tab) to move across. The European Commission (opens in a new tab) describes it as uniform rules for investment-based and lending-based crowdfunding for business financing, with an EU passport for platforms.
It now reaches further than the EU. Since 1 August 2026 (opens in a new tab) it has been in force in the EEA as well, which adds Iceland, Liechtenstein and Norway (opens in a new tab). The EFTA States' version gives existing national arrangements a further year.
How does a platform work across borders?
A provider applies where it is established (opens in a new tab). The regulator has 25 working days to check the file is complete and three months to decide.
To serve another country, it tells its home authority which states, who is responsible and when it will start. That is forwarded to the host state within 10 working days, and the provider can begin once it has been told so, or at the latest 15 calendar days (opens in a new tab) after submitting. ESMA's public register records which states each provider has notified. ESMA's market report (opens in a new tab) counted 229 providers with authorised status at the end of 2024, of which 181 raised money that year.
What stays national?
Marketing and language, mostly. Marketing has to be clearly identifiable (opens in a new tab), and in the host state's language or one it accepts, with no approval needed in advance. ESMA says only the national marketing rules of the state of dissemination (opens in a new tab) apply, and not several countries' rules at once.
The information sheet follows the same pattern: the home state's language, and if it is marketed elsewhere, that state's language or one it accepts. ESMA's tables (opens in a new tab) list each choice. France accepts French alone and says marketing there can only be in French, Germany and the Netherlands report no national marketing measures, and Spain accepts English beside Spanish.
Tax is left out entirely. The word does not appear (opens in a new tab) in the regulation, whose legal basis, Article 114 of the Treaty (opens in a new tab), excludes fiscal provisions. So reliefs and tax on gains are your own country's, and our country pages for Germany, France and the Netherlands note what we have read on each.
How much can a company raise?
Up to €5m over 12 months. The ceiling (opens in a new tab) adds together what one project owner has raised through crowdfunding platforms and certain public offers it made under a prospectus exemption. ESMA (opens in a new tab) says an offer above it is not covered by the regulation, and that the provider must check too.
What is the difference between a sophisticated and a non-sophisticated investor?
The protections below are mainly for non-sophisticated investors, which means everyone who is not sophisticated (opens in a new tab). A sophisticated investor is a professional client, or someone the platform has approved under Annex II.
An individual needs two of three: income of €60,000 or a portfolio over €100,000; a year working in finance or 12 months as an executive; or 10 significant trades a quarter over four quarters. A company needs one of: own funds of €100,000, turnover of €2m, or a balance sheet of €1m. Approval lasts two years (opens in a new tab).
What does a non-sophisticated investor have to do?
- An entry knowledge test. It comes before full access and is reviewed every two years (opens in a new tab). Failing brings a warning rather than a ban.
- A loss simulation. You work out your ability to bear loss, set at 10% of net worth, each year. Net worth is net income plus liquid assets less commitments (opens in a new tab), and the provider does not see the inputs. ESMA says it cannot be used to block you (opens in a new tab).
- Extra steps for larger sums. Above the higher of €1,000 or 5% of net worth in one offer, you get a warning, give explicit consent and show you understand the investment, each time. Here the rule does have teeth: if those are not met, ESMA says (opens in a new tab) the provider must prevent the investment.
- Four days to change your mind. You can revoke an offer to invest (opens in a new tab) for four calendar days from making it, with no reason and no penalty.
What is in the key investment information sheet?
The project owner writes it, in at most six A4 sides (opens in a new tab). Directly under its title it must say the offer has been "neither verified nor approved" by the competent authorities or ESMA. Its warning says the investment is not covered by the deposit guarantee schemes or investor compensation schemes, and advises against investing more than 10% of your net worth. How to evaluate a crowdfunding deal sets out what else to look for.
How much money actually crosses a border?
Not much. ESMA found (opens in a new tab) that 8% of funding in 2024 was raised cross-border, 5.8% from other EU and EEA countries and 2.2% from residents of third countries. Malta (100%), Estonia (77%) and Latvia (47%) were highest, and providers in Poland, Portugal, Romania and Slovakia served only domestic investors. Only a small proportion of funding in the largest markets came from non-residents.
So a passport does not mean a platform takes every country's investors. The regulation (opens in a new tab) permits it, and each provider chooses where to notify.
Can you invest on an ECSPR platform from outside the EU?
Not yet verified The rule binds platforms, not investors' residence. The definition of investor (opens in a new tab) has no residence test, and ESMA's figures (opens in a new tab) show that some third-country money does come in. Whether a resident of a non-EU country may invest depends on the platform's terms and that country's law. We found no ESMA statement on it.
The UK is not covered. The regulation was due to apply after the UK's transition period ended (opens in a new tab), so it did not carry over, and UK raises follow FCA rules instead. Switzerland is outside the EEA (opens in a new tab), and only a provider established in the EU can be authorised.
For the reverse question, Can non-US residents invest on Wefunder, StartEngine and Republic? covers the largest US platforms.
Is ECSPR about to change?
We cannot say. Article 45 (opens in a new tab) asked the Commission to report before 10 November 2023 on matters including the ceiling, the €1,000 step, the reflection period and cross-border volumes. We searched for that report and found none. The Commission's page (opens in a new tab) mentions no proposal to amend it, and the Publications Office (opens in a new tab) lists one amending act, the extension above. That is what we could find, and not proof that nothing is planned.
Frequently asked questions
Does ECSPR mean you can invest in any EU country from any other?
Not automatically. A provider has to notify each state it serves (opens in a new tab), and some serve only domestic investors (opens in a new tab).
Is there a maximum you can invest?
No fixed one. Non-sophisticated investors face extra steps (opens in a new tab) above the higher of €1,000 or 5% of net worth in one offer. That differs from the US rule, which sets a cap.
Can you sell an ECSPR investment on the platform?
A platform may run a bulletin board (opens in a new tab) where members advertise interest, but not a matching system. How to sell crowdfunded shares covers it.
Is the offer checked by a regulator?
No. The sheet has to say the offer has been neither verified nor approved (opens in a new tab). The provider verifies its completeness, correctness and clarity (opens in a new tab).
How many ECSPR raises can you see now?
We track 20 live ECSPR raises, and What is equity crowdfunding? compares the regime with the others.
Sources
- Regulation (EU) 2020/1503 on crowdfunding service providers (opens in a new tab)
- Delegated Regulation (EU) 2022/1988, extending the transition (opens in a new tab)
- EFTA, the regulation in the EEA Agreement (opens in a new tab)
- EFTA, the EEA Agreement (opens in a new tab)
- European Commission, Crowdfunding (opens in a new tab)
- ESMA, Q&A 2437 on the EUR 5m ceiling, 12 February 2025 (opens in a new tab)
- ESMA, Questions and answers on crowdfunding (opens in a new tab)
- ESMA, Market Report: Crowdfunding in the EU 2025 (opens in a new tab)
- ESMA, National rules on crowdfunding: tables, 27 July 2026 (opens in a new tab)
- Delegated Regulation (EU) 2022/2114, entry test and simulation (opens in a new tab)
- Publications Office, the regulation's record (opens in a new tab)
- Treaty on the Functioning of the EU, Article 114 (opens in a new tab)
- European Union (Withdrawal) Act 2018, section 3 (opens in a new tab)