SEIS / EIS Advance Assurance: Requirement to list potential investors

We cover the (chicken and egg!) situation regarding the requirement to include a list of names and addresses of potential investors on your advance assurance application to HMRC under the Seed Enterprise Investment Scheme (SEIS) and the Enterprise Investment Scheme (EIS).

Updated 21 September 2026. Read our SEIS advance assurance application guide for the full process. This page focuses on investor evidence. The current requirements are in HMRC VCM60230.

A company that has never raised investment under a qualifying venture capital scheme must demonstrate a credible intention and prospect of raising funds when applying for SEIS or EIS advance assurance. The evidence required depends on whether the company is raising directly or through an intermediary.

It's a bit of a Catch-22 situation...

The reason is that HMRC were in the past finding that they were having to deal with a large number of reviews of advance assurance applications that never came to fruition i.e. that never actually got investment. So huge amounts of HMRC resources were being committed to reviewing often 'speculative' applications and therefore, in an attempt to focus on the more 'genuine' and serious applications, this extra 'hurdle' was added.

For a direct raise, provide prospective investors' names, addresses and intended investment amounts. Fund manager, promoter and crowdfunding routes have different evidence requirements.

We often get asked whether this is REALLY necessary?

For a direct raise by a company that has never raised qualifying venture capital investment, prospective investor evidence is required. The test is not simply whether you have applied for advance assurance before.

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    Companies that have previously raised under a qualifying venture capital scheme are not automatically rejected for omitting prospective investor details, although the funding source can still be relevant. An application must give HMRC enough evidence to assess the proposed investment.

    If you're going to raise funding via a crowdfunding platform, then you need to provide evidence of letters or emails that you've exchanged with the crowdfunding platform to confirm that you have been accepted by them (even if this approval is subject to you getting clearance from HMRC via your advance assurance application).

    Prepare the fundraising evidence before submitting the application and check the requirements for your chosen route.

    For the cross-scheme application process, see HMRC's current advance assurance guidance.