ASIC Regulatory Guide 94 (RG 94) requires responsible entities to maintain documented valuation policies for each asset class in a managed investment scheme, with unlisted and illiquid holdings — including private equity and unlisted trust interests — typically requiring periodic independent valuation to support defensible unit pricing. Lever Impact provides independent, RG 94-aligned valuations for PE funds and unlisted trusts that incorporate climate and ESG risk into the valuation inputs as standard.
What RG 94 actually requires
ASIC Regulatory Guide 94, Unit pricing: Guide to good practice, sets out ASIC's expectations for how responsible entities (REs) calculate and apply unit prices for managed investment schemes. Its core requirement is that an RE must have a documented unit pricing policy covering, among other things, the valuation methodology applied to each class of asset the scheme holds. For liquid, exchange-traded holdings, that valuation is largely mechanical — the market provides the price. For unlisted and illiquid holdings — private equity interests, unlisted property, infrastructure, and other unit trust structures — there is no market price to reference, which is precisely where RG 94 places the heaviest expectation on the RE's valuation governance.
ASIC's guidance and related regulatory commentary on illiquid asset valuation make clear that REs are expected to apply valuation methodologies that are appropriate to the asset class, consistently applied, and capable of withstanding scrutiny — with periodic independent valuation widely regarded as the practical mechanism for meeting that expectation for unlisted holdings. An RE that marks unlisted PE interests to internally-generated estimates, without periodic independent review, carries a governance gap that becomes visible precisely when it matters most: at redemption, at an investor dispute, or under regulatory review.
Why unit pricing of unlisted PE and trust interests is harder than it looks
There is no reference price to anchor to
A listed security's unit price updates itself. An unlisted PE interest or unit trust holding has no equivalent — the valuation has to be built, not observed. That means the methodology, the inputs, and the judgement behind them carry the full weight of the number that ultimately determines what an investor pays to enter, or receives to exit, the fund.
Valuation frequency has to match the fund's unit pricing cycle
A fund that strikes unit prices daily or weekly cannot wait twelve months between independent valuations of its unlisted holdings without the gap itself becoming a governance issue. The valuation program needs to be structured — scheduled, recurring, and timed to the RE's own valuation policy — not treated as an annual compliance task disconnected from the unit pricing cycle.
The standard applied has to survive more than one audience
A PE fund unit pricing valuation is read by the fund's auditor, potentially by ASIC, and — in a dispute — potentially by a court. It also sits alongside financial reporting obligations under AASB 13 (Fair Value Measurement) or AASB 1056 (Superannuation Entities) where applicable. A valuation built only to satisfy an internal sign-off rarely survives that wider scrutiny.
Where climate and ESG risk now belong in a PE fund valuation
Most independent valuations of unlisted PE interests in Australia still treat climate and ESG factors as a qualitative commentary sitting beside the valuation — acknowledged, but not actually priced. That gap is becoming harder to justify. Where a portfolio company carries material physical or transition climate risk — exposure to the Safeguard Mechanism, high-emissions-intensity operations, or assets with embedded transition cost — that risk has a direct bearing on the cash flows, discount rate and terminal value that drive the valuation itself.
Lever Impact's approach treats climate and ESG risk as a valuation input, not a disclosure afterthought. Where material, physical and transition risk are reflected directly in the discounted cash flow and comparable-multiple analysis underpinning each unlisted holding — consistent with the same Four-Lever discipline (energy, water, community, policy) we apply across our sector research and deal advisory work. For funds holding portfolio companies now subject to mandatory AASB S2 climate disclosure, this also means the valuation and the portfolio company's own climate reporting are working from a consistent set of assumptions, rather than two unrelated documents prepared by two different teams.
This matters commercially, not just technically. A fund that can show its unit pricing valuations already reflect climate and transition risk is better positioned with institutional LPs who are themselves under increasing pressure to demonstrate climate risk integration across their own portfolios — and is less exposed to a valuation being revisited downward when a climate-related cost the valuation didn't anticipate eventually shows up in portfolio company cash flows.
What a defensible RG 94 valuation program looks like in practice
A documented valuation policy per asset class
Agreed with the responsible entity and reviewed periodically — not a one-off engagement letter. The policy sets out methodology, frequency and governance for each holding class the scheme carries.
A methodology appropriate to each holding
Income approach, market approach or net asset value, applied consistently period to period unless there is a documented reason to change. Methodology switches need a rationale, not a preference.
Valuation frequency aligned to the unit pricing cycle
Set to match how often the fund strikes prices, not arbitrarily defaulted to annual. A daily or weekly pricing fund needs a structured, scheduled program — not a valuation that ages for twelve months.
Material climate and transition risk in the inputs
Reflected in cash flows, discount rate or terminal value where it affects them — not carved out into a separate ESG note that sits beside the number.
Documented judgements and assumptions
So the valuation can withstand review by the fund's auditor, ASIC, or in the event of an investor dispute. The reasoning behind the number has to be as defensible as the number itself.
A genuinely independent valuer
Independent of the fund's transaction and deal execution function, so the valuation opinion is not influenced by a deal outcome. Independence is the whole point of an independent valuation.
The credentials behind Lever Impact's approach
Lever Impact's valuation work for PE funds and unlisted trusts is led by Tina Li, a Chartered Accountant who holds both the CFA Institute Climate Risk, Valuation, and Investing Certificate — an advanced credential in applying climate considerations to valuation and portfolio construction — and the CFA Institute Advanced Private Equity Certificate, covering advanced financial modelling, private debt valuation, due diligence and limited partner perspectives in private equity. That combination — chartered accounting valuation rigour, a private-equity-specific technical credential, and a formal qualification in climate-integrated valuation — is rare in the Australian independent valuation market, and it is the basis for treating climate and ESG risk as a genuine input into a PE fund valuation rather than a label attached after the number is already set.
Frequently asked questions
Independent Valuation • October 2026