The NAICS code for a private equity firm is 523940, Portfolio Management and Investment Advice. The Census Bureau's NAICS 2022 index lists "private equity fund managing" under this code. That covers the management company. The funds themselves are classified separately, usually under 525990, Other Financial Vehicles, and pure holding entities under 551112.
Key takeaways
- 523940 (Portfolio Management and Investment Advice) is the code for the PE firm itself, meaning the management company or GP entity that earns fees and carry. "Private equity fund managing" is an official index entry under this code in NAICS 2022.
- 525990 (Other Financial Vehicles) fits the funds. PE funds are closed-end pooled investment vehicles, and the 525990 index explicitly lists "closed-end investment funds" and "pooled investment vehicle (PIV) funds, closed-end."
- 523920 is retired. NAICS 2022 merged the old Portfolio Management code (523920) and Investment Advice code (523930) into 523940. Many older articles and filing services still cite 523920.
- The management company and the fund are different legal entities and should carry different codes. Most misclassification comes from ignoring this split.
- The SBA size standard for 523940 is $47 million in average annual receipts, which matters for SAM.gov registration and federal contracting.
Management company vs. fund: the distinction that decides the code
A private equity firm is not one entity. A typical structure has at least three:
- The management company (often an LLC) employs the team, collects the 2 percent management fee, and pays the bills. It actively manages portfolio assets for others, which is exactly what NAICS 523940 describes.
- The fund (usually a limited partnership) is the pooled capital itself. It has no employees and no operations. It exists to hold investments on behalf of LPs. That is a financial vehicle, not a portfolio manager, so it belongs in NAICS 525, and specifically 525990 because PE funds are closed-end: investors commit capital once and cannot redeem shares on demand. The neighboring code 525910 (Open-End Investment Funds) is for vehicles like open-end mutual funds that issue and redeem shares continuously at net asset value, which is the opposite of how a PE fund works.
- The general partner entity sits between the two. If it does the managing, 523940 fits. If it is a passive shell that only holds the GP interest, 551112 (Offices of Other Holding Companies) is the closer match.
When a form asks for one code and gives no room for nuance, use the code for the specific legal entity named on the form, not for the brand as a whole.
Which entity gets which code
| Entity type | NAICS code | Official title |
|---|---|---|
| PE management company / fund manager | 523940 | Portfolio Management and Investment Advice |
| The PE fund (closed-end LP) | 525990 | Other Financial Vehicles |
| Open-end investment fund (not typical PE) | 525910 | Open-End Investment Funds |
| Passive holding company (GP shell, acquisition holdco) | 551112 | Offices of Other Holding Companies |
| Placement agent, securities brokerage, underwriting | 523150 | Investment Banking and Securities Intermediation |
Two adjacent codes worth knowing: 523150 replaced the old 523110 (Investment Banking and Securities Dealing) in NAICS 2022, so it is the code for broker-dealer and placement activity, not for the PE firm itself. And 551112 explicitly excludes bank holding companies (551111) and holding companies that actively manage their subsidiaries (551114).
Where the code actually gets used
NAICS codes are self-assigned. There is no central registry, no approval process, and no penalty for a defensible choice. But the code you pick shows up in real places:
EIN applications (Form SS-4). The IRS asks for your principal activity when you request an EIN for the management company, the GP, and each fund. On partnership returns, the IRS uses its own principal business activity codes, where the closest match is 523900, a rolled-up version of the same category.
SBA size standards and federal contracting. To register in SAM.gov or self-certify as a small business, 523940 carries a $47 million average annual receipts ceiling, measured over five years. The more common way PE firms meet the SBA is through affiliation rules: a portfolio company majority-owned by a fund is affiliated with the fund's other portfolio companies, and their combined size can knock an otherwise small company out of small business set-asides.
Insurance underwriting. Carriers price D&O, E&O, and cyber policies partly off the applicant's industry code. A management company misfiled under a generic consulting code can end up with the wrong policy form or a coverage dispute.
Banking and state filings. Business bank account applications, state registrations, and beneficial ownership filings all ask for an industry classification, and lenders screen applications by NAICS.
Data providers and LPs also use these codes to segment the market, which is one reason firm-level data on private equity is noisy: thousands of managers are still filed under codes that no longer exist.
Don't use these outdated codes
The old draft of nearly every article on this topic points to 523920 (Portfolio Management) or 523910 (Miscellaneous Intermediation). As of NAICS 2022, 523920 no longer exists, and 523910 was never right for a fund manager. It covers principals trading on their own account, like investment clubs and individual dealers. A PE firm manages other people's money for a fee, which is the 523940 definition almost verbatim.
If a legacy system only accepts NAICS 2017 or 2012 codes, 523920 is the correct historical mapping for the management company. Everywhere else, use 523940.
The same classification logic applies across investment businesses. If you also run an RIA or family office, the analysis in our guide to the NAICS code for wealth management covers the same 523940 code from the advisory side, including where hedge fund managers land.
The bottom line
Classify the manager as 523940, the fund as 525990, and passive holding entities as 551112, and you will match the Census Bureau's own index. Getting this right takes five minutes and saves friction with the IRS, the SBA, insurers, and banks later.
For the investing side rather than the paperwork side, our private equity hub covers fund structures, fees, and access options for accredited investors, and the entrepreneurship hub covers classification and setup questions for operating businesses.
References
- U.S. Census Bureau. 2022 NAICS Definition, 523940 Portfolio Management and Investment Advice. https://www.census.gov/naics/?input=523940&year=2022&details=523940
- U.S. Census Bureau. 2022 NAICS Definition, 525990 Other Financial Vehicles. https://www.census.gov/naics/?input=525990&year=2022&details=525990
- U.S. Census Bureau. 2022 NAICS Definition, 525910 Open-End Investment Funds. https://www.census.gov/naics/?input=525910&year=2022&details=525910
- U.S. Census Bureau. 2022 NAICS Definition, 551112 Offices of Other Holding Companies. https://www.census.gov/naics/?input=551112&year=2022&details=551112
- U.S. Census Bureau. 2022 NAICS Definition, 523150 Investment Banking and Securities Intermediation. https://www.census.gov/naics/?input=523150&year=2022&details=523150
- U.S. Small Business Administration. Table of Size Standards, NAICS 523940. https://www.sba.gov/document/support-table-size-standards
- Internal Revenue Service. Instructions for Form 1065, Principal Business Activity Codes. https://www.irs.gov/instructions/i1065
Frequently asked questions
What NAICS code does a private equity fund itself use?
A private equity fund typically uses 525990, Other Financial Vehicles, which differs from the management company's code. PE funds are closed-end pooled investment vehicles, and the 525990 index explicitly lists closed-end investment funds and closed-end pooled investment vehicle funds. The fund is a financial vehicle with no employees or operations, so it does not belong under a portfolio-management code.
Is NAICS code 523920 still valid for private equity?
No, 523920 is retired. NAICS 2022 merged the old Portfolio Management code (523920) and Investment Advice code (523930) into 523940. Many older articles and filing services still cite 523920. If a legacy system only accepts NAICS 2017 or 2012 codes, 523920 is the correct historical mapping for the management company, but everywhere else use 523940.
Why does the management company get a different NAICS code than the fund?
They get different codes because they are different legal entities. The management company actively manages assets for others and collects fees, which fits 523940. The fund is pooled capital with no employees, a financial vehicle under 525990. A passive general partner shell that only holds the GP interest fits 551112. Most misclassification comes from ignoring this split.
What is the SBA size standard for NAICS 523940?
The SBA size standard for 523940 is $47 million in average annual receipts, measured over five years. It matters for SAM.gov registration and federal contracting. The more common way PE firms meet the SBA is through affiliation rules: a portfolio company majority-owned by a fund is affiliated with the fund's other portfolio companies, and their combined size can disqualify an otherwise small company.