# Incentive As

> Incentive As is an SEC-registered investment advisory firm in Oslo, Norway, registered since 2015, reporting $1 billion to $5 billion in regulatory assets under management in its Form ADV filing dated May 22, 2026.

- CRD: 174704
- Filed as: INCENTIVE AS
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Oslo, Norway
- Filing period: October 2026
- Form ADV filing dated: May 22, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/174704
- AdvisorCensus page: https://advisorcensus.com/firm/incentive-as-oslo-174704

## Quick answers

**How is Incentive As compensated?**
On its Form ADV (Item 5.E, October 2026), Incentive As reports these compensation arrangements: a percentage of assets under its management; performance-based fees.

**How much does Incentive As charge?**
Its Form ADV Part 2A brochure dated March 24, 2026 states: Asset-based fee: 0.8% to 1.25% a year (a range, as the brochure states it). Fees can differ by service and may be negotiable; the brochure is the complete statement.

**Where is Incentive As located?**
Incentive As' principal office is in Oslo, Norway, according to its Form ADV; the June 2026 filing also lists 1 other office (Schedule D, Section 1.F).

**Is Incentive As registered with the SEC or a state?**
Incentive As is an SEC-registered investment advisory firm, registered since 2015. Status as filed: Approved. CRD 174704.

**How much does Incentive As manage?**
Incentive As reports $2,464,314,430 in regulatory assets under management in its Form ADV filing dated May 22, 2026 (100% discretionary).

**How have Incentive As' assets and staff changed since 2021?**
In the Form ADV data for Incentive As: Regulatory assets under management: $1,657,203,472 in the October 2021 data and $2,464,314,430 in the October 2026 data, up 49%. Total employees: 5 in October 2021 and 6 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Incentive As serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (4); corporations or other businesses not listed above (4); sovereign wealth funds and foreign official institutions (1).

**Which custodians does Incentive As use?**
Incentive As' most recent Form ADV filing (Schedule D, Section 5.K(3)) lists The Bank of New York Mellon as a custodian holding 10% or more of its separately managed account assets.

**Does Incentive As report any disciplinary disclosures?**
Reports no disclosure items on Form ADV Item 11. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/174704

**What changed in Incentive As' recent Form ADV filings?**
In the April 2026 filing data: Changed its office addresses in Stockholm. Updated its list of owners and control persons (Schedule A).

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management
- Performance-based fees

### Fees and minimums (Form ADV Part 2A brochure dated March 24, 2026)

- Asset-based fee: 0.8% to 1.25% a year (a range, as the brochure states it)

> The Adviser deducts a management fee (the “Management Fee”), which generally ranges from 0.8% to 1.25% of the net asset value of each investor’s interest in such Funds.

As stated in the firm's brochure. Fees can differ by service and may be negotiable.

### Custodians (Schedule D, Section 5.K(3))
- The Bank of New York Mellon

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

### Regulatory assets under management (Item 5.F)
- Total: $2,464,314,430
- Discretionary: $2,464,314,430
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Pooled investment vehicles (other than investment companies and business development companies) | 4 | $1,640,850,473 |
| Sovereign wealth funds and foreign official institutions | 1 | $487,547,966 |
| Corporations or other businesses not listed above | 4 | $335,915,991 |

### Advisory services (Item 5.G)
- Portfolio management for pooled investment vehicles (other than investment companies)
- Portfolio management for businesses (other than small businesses) or institutional clients

### Firm details
- Registered since: 2015 (11 years)
- Employees: 6 total, 4 performing advisory functions
- Wrap fee program participation: No
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Other offices (Schedule D, Section 1.F), as of the June 2026 filing
- Stockholm

### Websites listed on Form ADV (Item 1.I)
- incentive.com

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $1,657,203,472 | 5 | March 31, 2021 |
| October 2022 | $2,649,166,764 | 5 | August 29, 2022 |
| October 2023 | $2,215,292,356 | 5 | July 31, 2023 |
| October 2024 | $2,383,412,066 | 6 | March 15, 2024 |
| October 2025 | $2,348,257,774 | 6 | March 28, 2025 |
| October 2026 | $2,464,314,430 | 6 | May 22, 2026 |

Regulatory assets under management: $1,657,203,472 in the October 2021 data and $2,464,314,430 in the October 2026 data, up 49%.
Total employees: 5 in October 2021 and 6 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Changed its office addresses in Stockholm.
- Updated its list of owners and control persons (Schedule A).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Incentive As (CRD 174704): Form ADV filing data as of October 2026.