Not always.
If you are a licensed European fund manager raising for your own funds, or an employee working inside that manager's licence, you need nothing further.
If you are independent and you raise money for someone else's fund from investors in Europe, you need a licence. Bringing investors and funds together is a licensed activity in Europe, and MiFID is the rulebook that says so. You either hold that licence yourself or you work as a tied agent under a firm that holds it.
Everything in between is decided by what you actually do, not by what the agreement is called.
Legal basis: Directive 2014/65/EU (MiFID II) and its implementation in each country.
There is a real difference between passing an investor's name to a manager, telling an investor which fund might suit them, discussing a specific fund and its terms, answering the investor's questions about it, sending them subscription documents, and taking their commitment back to the manager. The further down that list your work sits, the harder it is to argue you are outside the licensed activity. Describe the work in those terms before anyone reaches for a label.
Are you the licensed fund manager, an employee inside it, an employee of a different company in the group, or your own business? A manager's licence covers its own organisation. It does not stretch to a separate company, however close the commercial relationship is.
Whether the fund itself may be offered in the target country is a separate question, and it also needs an answer. Professional or institutional investors change how you must deal with them. They do not make the activity unlicensed.
Where you are decides where you would be registered. Where the investors are decides which market you are selling into. Both matter, and they are different questions.
Introduction fee, success fee, retainer, consultancy fee. None of it changes what you did to earn the money.
An advisory or consultancy agreement covering sales work is a sales arrangement with the wrong heading on it.
A sophisticated counterparty changes your conduct duties. It does not remove the licence.
That is a narrow exception with a high bar, judged against everything that happened before and after. It is not a business model.
You hold the permissions in your own name. You also carry the capital requirement, the governance, the named senior people, the reporting and the audit. This is right if you need permissions beyond bringing investors and funds together, or if being the licensed firm is part of what you sell.
A licensed investment firm appoints you, you go into a public register, and you work in that firm's name and under its responsibility. You hold no licence of your own and you may work for one firm only. This is right if your work sits inside brokerage and your own licence would cost more than it earns.
Legal basis for the second route: Article 29 MiFID II.
The fee is not the test. What you did is. Naming a specific fund, discussing its terms, sending documents, or walking an investor towards a subscription all point to a licensed activity, and being paid when the subscription completes strengthens that reading rather than weakening it. Passing a name with no discussion of any product is a different case. If your work sits on the first list, assume you need the arrangement in place before the next call.
If your employer is the licensed manager and you work inside its permissions and its supervision, no. If you are employed by a different company in the group, that company's position is what matters, not the manager's.
No. What counts is the work performed under the agreement, not the title on the front page.
From first call to operational: 7 to 12 weeks where the tied agent is established in Germany, and 10 to 16 weeks where the tied agent is established in another EEA state. Both are best case ranges, and the clock starts once your due diligence documents are complete.
substnz Capital Partners GmbH appoints tied agents to bring professional and institutional investors and funds together across eighteen European markets. If your work sits inside that, this is the route that avoids applying for your own licence. If it does not, we will say so rather than stretch the arrangement to fit.