FIPVCC Compliance Guide: Step-by-Step for Venture Capital Firms

Step 1: Determine If You Are Covered

FIPVCC applies to venture capital companies with a California nexus. Ask yourself:

• Is your firm headquartered or operating in California?
• Do you invest in California-based companies?
• Does your firm meet the statutory definition of a "venture capital company" under Corp. Code section 27500?

If the answer to any of these is yes, you are likely covered. Consult legal counsel or contact the DFPI at VCC_Support@dfpi.ca.gov if you are uncertain.

Step 2: Identify Your Portfolio Companies and Founding Teams

Create an inventory of all companies your firm has invested in. For each company, identify the founding team members — founders, co-founders, and executive leadership team members — who should receive the demographic survey.

FairVC automates this: Use the portfolio management feature to add companies and team members. Track investment amounts, dates, and team composition in one centralized platform.

Step 3: Distribute the Demographic Survey

Send a voluntary demographic survey to each founding team member. The survey must cover:

• Race and ethnicity (multiple selections allowed)
• Gender identity
• Sexual orientation / LGBTQ+ status
• Disability status
• Veteran status
• California residency

Participation is entirely voluntary. Founders may decline to respond to any or all questions. The survey must clearly communicate that participation is optional and that data will be aggregated and anonymized.

FairVC automates this: Send personalized survey invitations via email with one click. Track delivery status, opens, and completions in real time. Surveys expire after 60 days per FIPVCC requirements.

Step 4: Collect and Securely Store Responses

As founders complete surveys, securely store their demographic responses. Given the sensitivity of this data (race, gender, sexual orientation, disability, veteran status), robust data security is essential.

FairVC automates this: All survey responses are encrypted with AES-256-GCM encryption at rest. Individual responses are never exposed in plain text — only authorized, aggregated views are available. Learn more about our data security practices.

Step 5: Calculate Diversity Metrics

Under Corp. Code § 27500(d), the DFPI report requires you to determine whether each portfolio company is "primarily founded by diverse founding team members." This requires:

• A sufficient survey response rate (typically >50%)
• Analysis of whether ≥50% of respondents identify as members of underrepresented groups
• Category-level breakdowns for gender, race/ethnicity, LGBTQ+, disability, and veteran status

FairVC automates this: Diversity metrics are calculated automatically per the statutory formula. The analytics dashboard shows real-time diversity breakdowns across your entire portfolio.

Step 6: Generate and Submit Your DFPI Report

By April 1 each year (starting April 1, 2026), submit your Venture Capital Demographic Data Report to the DFPI. The report includes:

• Part One: Aggregate demographic responses across all portfolio companies
• Part Two: Investment analysis by diversity status (number and dollar amount of investments in companies primarily founded by diverse vs. non-diverse teams)
• Part Three: Portfolio company listings with investment details

FairVC automates this: Generate a PDF report matching the official DFPI template with one click. Download and submit it through the DFPI portal. See our detailed DFPI reporting requirements guide.

Step 7: Retain Records

Maintain records of your compliance activities — survey distributions, responses, reports submitted, and related correspondence. Good record-keeping demonstrates diligence and supports you in the event of a DFPI inquiry.

FairVC automates this: The platform provides 5-year data retention (Annual plan), activity audit logs tracking every compliance action, and email event tracking for survey distributions — giving you a complete, auditable compliance record.