Legal development

Suspension of enforcement of California’s Fair Investment Practices by Venture Capital Companies Law

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    This Legal Development was updated on October 6, 2026.

    Key takeaways 

    • California announced on March 17, 2026, that it is suspending implementation and enforcement of the Fair Investment Practices by Venture Capital Companies Law (FIPVCC), which would require certain venture capital firms with sufficient ties to California to collect and annually report demographic and diversity-related information.  
    • Covered entities were expected to register and begin reporting with the California Department of Financial Protection and Innovation (DFPI) by April 1, 2026, but DFPI has confirmed that deadline is no longer required. 
    • DFPI suspended implementation and enforcement pending rulemaking and final regulations to clarify key definitions, scope, and operational requirements. 
    • The suspension appears to be a temporary pause, so covered entities should monitor developments and prepare to assess compliance obligations. 

    On March 17, 2026, California announced that it would suspend enforcement of the FIPVCC until further notice. 

    What is the California FIPVCC?

    The FIPVCC, as drafted, requires certain venture capital firms with sufficient ties to California to collect and annually report demographic and diversity-related information regarding their investment activities. As originally contemplated, covered entities were expected to register with the California DFPI and begin reporting by April 1, 2026. 

    Why did the DFPI suspend the FIPVCC?

    The DFPI announced that implementation and enforcement of the FIPVCC will be suspended pending completion of a rulemaking process and the adoption of final regulations. The DFPI has confirmed that it will therefore not require covered entities to submit registrations or file reports by the April 1, 2026, deadline.

    This pause reflects the DFPI’s recognition that additional regulatory clarity is needed, with the regulated industry seeking guidance on key definitions, the scope of covered entities, and operational requirements for compliance. 

    What's next?

    While this suspension offers a temporary reprieve, covered entities should not view it as a permanent withdrawal of the FIPVCC's requirements as California remains steadfast in its desire to seek demographic information from regulated parties. DFPI has indicated it will seek input from relevant parties over the next few months before beginning formal rulemaking.

    Venture capital firms and other potentially covered entities should continue to monitor DFPI communications closely, preserve any demographic and investment data already collected in anticipation of future reporting obligations, and evaluate their internal compliance infrastructure in light of the forthcoming regulatory framework. We will continue to track developments and provide updates as the rulemaking process progresses. 

    Frequently asked questions

    What is the California FIPVCC?  

    The California Fair Investment Practices by Venture Capital Companies Law (FIPVCC) would require certain venture capital firms with California ties to collect and annually report demographic and diversity information about their investments.  

    Is the California FIPVCC law in effect?  

    The Fair Investment Practices by Venture Capital Companies Law (FIPVCC) law remains in effect, but the California Department of Financial Protection and Innovation (DFPI) suspended implementation and enforcement pending rulemaking and final regulations. DFPI will not require registrations or reports by the original April 1, 2026, deadline. 

    The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to.
    Readers should take legal advice before applying it to specific issues or transactions.

    Editorial Disclaimer

    Originally published before the Ashurst Perkins Coie combination. See disclaimer.

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