How to Track Information Rights Across a Portfolio

How to track information rights is a delivery ledger, not a thesis that reporting matters. For each company, log which reports the Investors' Rights Agreement (or a side letter) actually requires (annual, quarterly, monthly, budget, cap table), the due date after period end copied from that paper, whether the file arrived, and whether the right is major-investor-only. Raziel's pro-rata rights tracking page is the other IRA clock: the notice window and cash to keep the percentage. This page is the reporting book.

This is not legal, tax, or investment advice. Raziel does not provide it. Copy the signed section. Do not invent a day count.

What this delivery ledger is (and is not)

The NVCA Model Investors' Rights Agreement (updated October 2025) puts information rights in Section 3.1 and inspection in Section 3.2. Delivery is to each Major Investor (optional competitor carve-out). Major Investor means any Investor that, individually or together with Affiliates, holds at least a blank, negotiated number of Registrable Securities. The model prints no dollar default. NVCA's model set is a starting point only, not legal advice for particular facts. Morrison Foerster's Ask a MoFo series: the IRA package commonly includes some or all of annual financials, quarterly unaudited statements, a quarterly capitalization table, optional monthly statements, an annual budget, and a catch-all, typically limited to Major Investors.

Cooley GO's term-sheet guide (last reviewed January 23, 2022) lists information rights among provisions founders can often de-prioritize at the sheet unless they are really concerned about sharing. Cooley GO: an MRL is a short side letter that can add consultation, examination of books and records, inspection of facilities, and sometimes board materials. Extra information rights that live only in a side letter are a different row. Raziel's side-letter tracking page is that file map. Carta (The Carta Team, February 27, 2025): companies share financial reports and cap table access from an Investor Relations hub. Arrival can be a platform upload. The October 2025 NVCA form: if reasonably requested by a Major Investor, the company shall upload Section 3.1 information to a portfolio management platform. Nixon Peabody (December 12, 2025): that form relocated the annual budget requirement and clarified no obligation to create new information.

Seven columns on one information-rights row

Open one row per issuer per source document. An IRA Section 3.1 package and a side-letter extra are different rows. Copy each field. If a field is missing, store that it was missing.

• Source document. Investors' Rights Agreement versus side letter (including an MRL). Store the file, date, and section.

• Major-investor threshold and whether you qualify. Copy the share (or dollar) cut. NVCA prints a blank share count of Registrable Securities. Compare your holdings (with Affiliates, if the definition counts them). Yes, no, or fell below.

• List of required deliveries, copied from the IRA. Annual (audited only if that bracket closed), quarterly unaudited, monthly (only if the optional clause is in), annual budget or Approved Annual Budget, and cap table or capitalization statement.

• Contractual due date after period end. Compute from the copied day count plus that period's end.

• Date received versus missing. Date the file hit email, data room, or portfolio platform. If the due date passed with no file, mark missing.

• Inspection / visitation right. Yes/no pointer to Section 3.2 (or the side letter). NVCA model: each Major Investor, at its expense, during normal business hours, as reasonably requested to monitor the investment.

• Confidentiality overlay. Pointer to the IRA confidentiality covenant (Section 3.5 in the October 2025 NVCA form) or the side letter. Use is to monitor or make decisions on the investment, plus the paper's permitted-disclosure list.

Copy the model clocks, not a blog default

Do not invent a 30-day, 45-day, or 90-day industry standard. The signed document is the clock. The October 2025 NVCA Model IRA Word file (fetched from NVCA) illustrates one Section 3.1 package with printed day counts and bracketed fill-ins:

• Annual financials. Within 180 days after fiscal year-end: balance sheet, income and cash flows, stockholders' equity, GAAP. Audit is bracketed.

• Quarterly unaudited. Within 45 days after each quarter-end: unaudited income, cash flows, and balance sheet.

• Capitalization statement. Within 45 days after each quarter-end, enough detail for Major Investors to calculate percentage ownership.

• Monthly unaudited. Entire clause bracketed. If it survived, within 30 days after month-end.

• Approved Annual Budget. As soon as practicable. Preparation "at least 30 days before the end of each fiscal year" is bracketed.

Nixon Peabody's overview still describes annual delivery within 90-120 days and quarterly within 45. Morrison Foerster describes annual statements typically within 90-180 days after fiscal year-end. Commentary, not this company's clock. Copy the PDF.

When the ledger holds

The row holds if source is named, the Major Investor cut and your qualify flag are copied, each required delivery and due date come from the PDF, received versus missing is a date or a gap, and inspection and confidentiality are yes/no pointers. It fails when you assume rights the IRA never granted, paste 180 or 45 as this company's clock, or collapse a side-letter extra into the IRA row. NVCA Section 3.4 (October 2025) ends Sections 3.1 and 3.2 immediately before the IPO (Direct Listing is bracketed), while an Investor is a Sanctioned Party, at Exchange Act Section 12(g) or 15(d) reporting, or on a Deemed Liquidation Event under stated conditions. If rights terminated, close the row.

A workbook can hold these columns. It fails when files land in three inboxes with no received date. Raziel's startup investment tracker is the book those files should sit on: documents, dates, cap tables, IRR and MOIC. Raziel does not interpret your IRA. Copy the seven columns.