# Regulation s offshore: Holder Eligibility Regimes

> The Holder Eligibility Regimes carries 4 published figures read from 1 source's own page, from 100,000 to 43,000,000 EUR, read 17 October 2026.

Bags That Pay · https://bagsthatpay.com/datasets/holder-eligibility-regimes/ · computed 2026-10-18

**Range of the published figures:** 100,000 to 43,000,000 EUR (range 100,000 to 43,000,000 EUR; 4 published figures; 3 of 18 sources read publish one).

3 of the 18 named sources read in full publish a figure; 15 publish none, read 17 October 2026.

## By investor class

| Breakdown | Median | Range | Sources |
|---|---|---|---|
| investor class qualified institutional buyer | 100 USD | 100 to 100 USD | 1 |
| investor class per se professional body corporate | 5 GBP | 5 to 5 GBP | 1 |
| investor class per se professional partnership | 5 GBP | 5 to 5 GBP | 1 |
| investor class minimum consideration exemption | 100,000 EUR | 100,000 to 100,000 EUR | 1 |
| investor class large undertaking balance sheet test | 43,000,000 EUR | 43,000,000 to 43,000,000 EUR | 1 |
| investor class national exemption ceiling (EUR 5m option) | 5,000,000 EUR | 5,000,000 to 5,000,000 EUR | 1 |
| investor class national exemption ceiling (EUR 12m option) | 12,000,000 EUR | 12,000,000 to 12,000,000 EUR | 1 |

## Every figure, with its source

One row per source: the figure the source's own page publishes, the page, and the day it was read.

| Source | Figure | Breakdown | Read |
|---|---|---|---|
| [EUR-Lex - Regulation (EU) 2017/1129 consolidated](https://eur-lex.europa.eu/eli/reg/2017/1129/2026-06-05/eng) | 43,000,000 EUR | large undertaking balance sheet test | 2026-10-17 |
| [EUR-Lex - Regulation (EU) 2017/1129 consolidated](https://eur-lex.europa.eu/eli/reg/2017/1129/2026-06-05/eng) | 12,000,000 EUR | national exemption ceiling (EUR 12m option) | 2026-10-17 |
| [EUR-Lex - Regulation (EU) 2017/1129 consolidated](https://eur-lex.europa.eu/eli/reg/2017/1129/2026-06-05/eng) | 5,000,000 EUR | national exemption ceiling (EUR 5m option) | 2026-10-17 |
| [EUR-Lex - Regulation (EU) 2017/1129 consolidated](https://eur-lex.europa.eu/eli/reg/2017/1129/2026-06-05/eng) | 100,000 EUR | minimum consideration exemption | 2026-10-17 |
| [SEC - modernising the accredited investor definition](https://www.sec.gov/newsroom/press-releases/2020-191) | 100 USD | qualified institutional buyer | 2026-10-03 |
| [FCA Handbook COBS 3.5 - professional clients](https://handbook.fca.org.uk/handbook/cobs3/cobs3s5) | 5 GBP | per se professional body corporate | 2026-10-17 |
| [FCA Handbook COBS 3.5 - professional clients](https://handbook.fca.org.uk/handbook/cobs3/cobs3s5) | 5 GBP | per se professional partnership | 2026-10-17 |

## The sentence each figure was read from (7)

- [EUR-Lex - Regulation (EU) 2017/1129 consolidated](https://eur-lex.europa.eu/eli/reg/2017/1129/2026-06-05/eng), read 2026-10-17: "companies, which, according to their last annual or consolidated accounts, meet at least two of the following three criteria: an average number of employees during the financial year of less than 250, a total balance sheet not exceeding EUR 43 000 000 and an annual net turnover not exceeding EUR 50 000 000 ;"
- [EUR-Lex - Regulation (EU) 2017/1129 consolidated](https://eur-lex.europa.eu/eli/reg/2017/1129/2026-06-05/eng), read 2026-10-17: "Member States shall also notify the Commission and ESMA where they subsequently decide to adopt instead the exemption threshold of EUR 12 000 000 referred to in paragraph 2, point (b)."
- [EUR-Lex - Regulation (EU) 2017/1129 consolidated](https://eur-lex.europa.eu/eli/reg/2017/1129/2026-06-05/eng), read 2026-10-17: "Member States shall notify the Commission and ESMA where they decide to adopt the exemption threshold of EUR 5 000 000 laid down in paragraph 2a."
- [EUR-Lex - Regulation (EU) 2017/1129 consolidated](https://eur-lex.europa.eu/eli/reg/2017/1129/2026-06-05/eng), read 2026-10-17: "an offer of securities addressed to investors who acquire securities for a total consideration of at least EUR 100 000 per investor, for each separate offer;"
- [SEC - modernising the accredited investor definition](https://www.sec.gov/newsroom/press-releases/2020-191), read 2026-10-03: "The amendments expand the definition of “qualified institutional buyer” in Rule 144A to include limited liability companies and RBICs if they meet the $100 million in securities owned and invested threshold in the definition."
- [FCA Handbook COBS 3.5 - professional clients](https://handbook.fca.org.uk/handbook/cobs3/cobs3s5), read 2026-10-17: "a body corporate (including a limited liability partnership) which has (or any of whose holding companies or subsidiaries has) (or has had at any time during the previous two years) called up share capital or net assets of at least £5 million (or its equivalent in any other currency at the relevant time);"
- [FCA Handbook COBS 3.5 - professional clients](https://handbook.fca.org.uk/handbook/cobs3/cobs3s5), read 2026-10-17: "a partnership or unincorporated association which has (or has had at any time during the previous two years) net assets of at least £5 million (or its equivalent in any other currency at the relevant time) and calculated in the case of a limited partnership without deducting loans owing to any of the partners; ension scheme, SSAS, personal pension scheme or stakeholder pension scheme) which has (o"

## Read in full, publishes no figure

- [eCFR 17 CFR 230.501 - definitions used in Regulation D](https://www.ecfr.gov/current/title-17/chapter-II/part-230/subject-group-ECFR6e651a4c86c0174/section-230.501), read 2026-10-03: read in full and no accepted figure on the page
- [eCFR 17 CFR 230.506 - Rule 506 exemption](https://www.ecfr.gov/current/title-17/chapter-II/part-230/subject-group-ECFR6e651a4c86c0174/section-230.506), read 2026-10-03: read in full and no accepted figure on the page
- [eCFR 17 CFR 230.215 - accredited investor](https://www.ecfr.gov/current/title-17/chapter-II/part-230/section-230.215), read 2026-10-17: read in full and no accepted figure on the page
- [eCFR 17 CFR 270.2a51-1 - qualified purchaser](https://www.ecfr.gov/current/title-17/chapter-II/part-270/section-270.2a51-1), read 2026-10-17: read in full and no accepted figure on the page
- [SEC - offshore offers and sales (Regulation S)](https://www.sec.gov/rules-regulations/1998/02/offshore-offers-sales-regulation-s-effective-date-60-days-after-publication-federal-register), read 2026-10-17: every candidate on the page was refused
- [SEC investor.gov - accredited investor bulletin](https://www.investor.gov/introduction-investing/general-resources/news-alerts/alerts-bulletins/investor-bulletins/updated-3), read 2026-10-17: every candidate on the page was refused
- [FCA Handbook glossary - professional client](https://handbook.fca.org.uk/glossary/G1979), read 2026-09-26: read in full and no accepted figure on the page
- [Regulation (EU) 2017/1129 as assimilated in UK law](https://www.legislation.gov.uk/eur/2017/1129/chapter/I), read 2026-09-12: read in full and no accepted figure on the page
- [MAS - FAQs on the accredited investor definition and opt-in](https://www.mas.gov.sg/regulation/faqs/faqs-on-the-definition-of-accredited-investor-and-opt-in-process), read 2026-09-12: read in full and no accepted figure on the page
- [CIMA - Cayman Islands investment funds](https://www.cima.ky/investment-funds), read 2026-09-12: read in full and no accepted figure on the page
- [CIMA - investment funds licensing requirements](https://www.cima.ky/investment-funds-licensing-authorisation-requirements), read 2026-09-12: read in full and no accepted figure on the page
- [BVI FSC - professional funds](https://www.bvifsc.vg/terms/regulated-entities/professional-funds), read 2026-09-12: read in full and no accepted figure on the page
- [FMA Liechtenstein - Token and TT Service Provider Act](https://www.fma-li.li/en/supervision-regulation/fintech/tvtg), read 2026-09-12: read in full and no accepted figure on the page
- [Swiss State Secretariat for International Finance - DLT and tokenisation](https://www.sif.admin.ch/en/dlt-blockchain-en), read 2026-09-12: read in full and no accepted figure on the page
- [FINMA - first DLT trading facility licensed](https://www.finma.ch/en/news/2025/03/20250318-mm-dlt-handelssystem/), read 2026-09-12: read in full and no accepted figure on the page

## Methodology

Every row is a verbatim sentence read from the named source's own page through our fetch service on the date shown, hash-pinned to the stored read (the sha of the page's visible text; the raw page is mirrored to R2). 3 of the 18 named sources that could be read published a usable figure; 15 published none and are recorded as not published, never filled in; 0 could not be read (blocked, dead or unreachable) and count nowhere. The headline figures (median, minimum, maximum, quartiles) are over ONE figure per source for each breakdown it prices, in EUR (a source's median where its page yielded several accepted sentences for one breakdown), so a page that gives figures for several breakdowns gives one for each and N counts 4 figures, never sentences; 30 candidate sentence(s) were refused by a reviewer with the reason recorded. The fuller derivation this dataset is chartered to grow into (not yet what the figures above are; they are each source's own published figure as read): one row per jurisdiction per investor class: the threshold and the test quoted verbatim from the authority with the date read, beside the fund or token regime a tokenized product is issued under there (Reg D/Reg S and 3(c)(7) in the US, the Prospectus Regulation's qualified investor in the EU, COBS 3.5 in the UK, the MAS accredited-investor opt-in in Singapore, CIMA's registered fund in Cayman, the BVI professional fund, Liechtenstein's TVTG, the Swiss DLT Act). The derivation is the CROSS-JURISDICTION comparison joined to the register: which tokens a person in this jurisdiction may hold, and which threshold decides it.

## Sources

- [eCFR 17 CFR 230.501 - definitions used in Regulation D](https://www.ecfr.gov/current/title-17/chapter-II/part-230/subject-group-ECFR6e651a4c86c0174/section-230.501) (the publisher's own terms; quoted for reporting and comment)
- [eCFR 17 CFR 230.506 - Rule 506 exemption](https://www.ecfr.gov/current/title-17/chapter-II/part-230/subject-group-ECFR6e651a4c86c0174/section-230.506) (the publisher's own terms; quoted for reporting and comment)
- [eCFR 17 CFR 230.215 - accredited investor](https://www.ecfr.gov/current/title-17/chapter-II/part-230/section-230.215) (the publisher's own terms; quoted for reporting and comment)
- [eCFR 17 CFR 270.2a51-1 - qualified purchaser](https://www.ecfr.gov/current/title-17/chapter-II/part-270/section-270.2a51-1) (the publisher's own terms; quoted for reporting and comment)
- [SEC - modernising the accredited investor definition](https://www.sec.gov/newsroom/press-releases/2020-191) (the publisher's own terms; quoted for reporting and comment)
- [SEC - offshore offers and sales (Regulation S)](https://www.sec.gov/rules-regulations/1998/02/offshore-offers-sales-regulation-s-effective-date-60-days-after-publication-federal-register) (the publisher's own terms; quoted for reporting and comment)
- [SEC investor.gov - accredited investor bulletin](https://www.investor.gov/introduction-investing/general-resources/news-alerts/alerts-bulletins/investor-bulletins/updated-3) (the publisher's own terms; quoted for reporting and comment)
- [FCA Handbook COBS 3.5 - professional clients](https://handbook.fca.org.uk/handbook/cobs3/cobs3s5) (the publisher's own terms; quoted for reporting and comment)
- [FCA Handbook glossary - professional client](https://handbook.fca.org.uk/glossary/G1979) (the publisher's own terms; quoted for reporting and comment)
- [Regulation (EU) 2017/1129 as assimilated in UK law](https://www.legislation.gov.uk/eur/2017/1129/chapter/I) (the publisher's own terms; quoted for reporting and comment)
- [MAS - FAQs on the accredited investor definition and opt-in](https://www.mas.gov.sg/regulation/faqs/faqs-on-the-definition-of-accredited-investor-and-opt-in-process) (the publisher's own terms; quoted for reporting and comment)
- [CIMA - Cayman Islands investment funds](https://www.cima.ky/investment-funds) (the publisher's own terms; quoted for reporting and comment)
- [CIMA - investment funds licensing requirements](https://www.cima.ky/investment-funds-licensing-authorisation-requirements) (the publisher's own terms; quoted for reporting and comment)
- [BVI FSC - professional funds](https://www.bvifsc.vg/terms/regulated-entities/professional-funds) (the publisher's own terms; quoted for reporting and comment)
- [FMA Liechtenstein - Token and TT Service Provider Act](https://www.fma-li.li/en/supervision-regulation/fintech/tvtg) (the publisher's own terms; quoted for reporting and comment)
- [Swiss State Secretariat for International Finance - DLT and tokenisation](https://www.sif.admin.ch/en/dlt-blockchain-en) (the publisher's own terms; quoted for reporting and comment)
- [FINMA - first DLT trading facility licensed](https://www.finma.ch/en/news/2025/03/20250318-mm-dlt-handelssystem/) (the publisher's own terms; quoted for reporting and comment)
- [EUR-Lex - Regulation (EU) 2017/1129 consolidated](https://eur-lex.europa.eu/eli/reg/2017/1129/2026-06-05/eng) (the publisher's own terms; quoted for reporting and comment)

## Cite or embed

- The Holder Eligibility Regimes carries 4 published figures read from 1 source's own page, from 100,000 to 43,000,000 EUR, read 17 October 2026.
- 3 of the 18 named sources read in full publish a figure; 15 publish none, read 17 October 2026.
- Holder Eligibility Regimes, investor class qualified institutional buyer: median 100 USD across 1 source, read 17 October 2026.
- Holder Eligibility Regimes, investor class per se professional body corporate: median 5 GBP across 1 source, read 17 October 2026.
- Holder Eligibility Regimes, investor class per se professional partnership: median 5 GBP across 1 source, read 17 October 2026.
- Holder Eligibility Regimes, investor class minimum consideration exemption: median 100,000 EUR across 1 source, read 17 October 2026.
- Holder Eligibility Regimes, investor class large undertaking balance sheet test: median 43,000,000 EUR across 1 source, read 17 October 2026.
- Holder Eligibility Regimes, investor class national exemption ceiling (EUR 5m option): median 5,000,000 EUR across 1 source, read 17 October 2026.
- Holder Eligibility Regimes, investor class national exemption ceiling (EUR 12m option): median 12,000,000 EUR across 1 source, read 17 October 2026.

Cite as: "Bags That Pay Holder Eligibility Regimes", updated 2026-10-18, https://bagsthatpay.com/datasets/holder-eligibility-regimes/.

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