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Spousal equivalents and accredited status

The short answer. You do not have to be legally married to combine finances for the accredited investor tests. Since the SEC's 2020 amendments, you can pool income or net worth with a spousal equivalent - a cohabitant in a relationship generally equivalent to that of a spouse. That means unmarried partners, domestic partners, and civil-union partners can reach $300,000 joint income or $1 million combined net worth together, and only one of you needs to make the investment.

What changed in 2020

The accredited investor rules have long let a married couple combine income or net worth to clear the joint thresholds. What they did not do - until the SEC's 2020 amendments - was define "spouse" or extend that pooling to unmarried partners. The 2020 update fixed that by adding the term spousal equivalent to Rule 501, and letting a person combine finances with a spousal equivalent for the joint income and joint net worth tests.

The SEC defines a spousal equivalent as "a cohabitant occupying a relationship generally equivalent to that of a spouse." SEC, 2020 amendments to the accredited investor definition (Rule 501)

The SEC described the change as capturing relationships such as domestic partnerships and civil unions, and it applies regardless of the partners' genders. In short: the test looks at the substance of the relationship, not a marriage certificate.

How the combined tests work

With a spouse or spousal equivalent, you can qualify on either joint test - you only need one:

Two details matter. First, if you qualify on joint income, you generally must use the $300,000 joint threshold rather than mixing one partner's individual income with joint assets in a way the rule does not allow. Second, and more usefully: you do not have to invest jointly. The securities can be bought by just one partner even though the qualification rests on the couple's combined figures.

Who counts as a spousal equivalent

The definition is deliberately about the relationship, not its legal label. A spousal equivalent is a cohabitant in a relationship generally equivalent to that of a spouse. That typically includes a long-term domestic partner you live with and share finances with. It would not include a roommate, a relative, or a business partner - the point is a marriage-like partnership, just without the marriage.

If you are not relying on a partner at all, the individual accredited investor tests (income over $200,000, net worth over $1 million, or a Series 7, 65, or 82 license) still apply on their own.

Documenting it in a verification

When a sponsor verifies you under Rule 506(c) on a joint basis, the review looks at both partners' relevant evidence - income documents for the income test, or combined assets and liabilities for the net worth test - plus a representation about the spousal-equivalent relationship. With a CPA letter, all of that goes to the CPA, and the sponsor receives only the signed conclusion that you qualify, with no financial figures and no disclosure of either partner's documents. See the sample verification letter for what that looks like, or the documents a verification needs.

Qualify together, verify privately

A licensed CPA reviews your and your partner's documents and signs a verification letter - usually within 24 hours. Neither partner's financials go to the sponsor.

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Common questions

What is a spousal equivalent for accredited investor purposes?
A spousal equivalent is a cohabitant occupying a relationship generally equivalent to that of a spouse. The SEC added the term to the accredited investor rules in 2020 so that unmarried partners - including domestic partners and those in civil unions - can combine their finances for the joint income and joint net worth tests, the same way a married couple can.
Can unmarried partners combine income or net worth to be accredited?
Yes. Since the SEC's 2020 amendments, a person and their spousal equivalent may pool resources to meet the accredited investor thresholds - joint income over $300,000 in each of the last two years, or combined net worth over $1 million excluding a primary residence. The couple does not have to be legally married, and the investment does not have to be purchased jointly.
Do we have to invest jointly to use the spousal-equivalent route?
No. The accredited investor rules let you count joint income or joint net worth even if only one partner makes the investment. The securities do not need to be held jointly. What matters is that the combined figures meet the threshold and that the person you are combining with is a spouse or spousal equivalent as the SEC defines it.
How do you document a spousal-equivalent verification?
A verification based on joint figures reviews both partners' relevant documents - joint or individual income documents for the income test, or combined assets and liabilities for the net worth test - along with a representation about the spousal-equivalent relationship. With a CPA letter, the CPA reviews that evidence privately and the sponsor receives only the signed conclusion, without seeing either partner's financial figures.

This page is general educational information about the SEC accredited investor definition (17 CFR § 230.501(a)), not legal, tax, or investment advice. The spousal-equivalent provision and the joint income and net worth tests have conditions beyond this summary; confirm how they apply to your situation with your own advisers. AccreditedNow is not a law firm.