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Why an IPS is essential for emerging technology
An IPS is a decision framework, not a list of fashionable technologies. Northern Trust describes it as a source of strategic direction and role clarity for family-office decisions. Trish Halper, its Practice Executive for Family Office Investments, calls an IPS “a rudder” that keeps the office on course while allowing adjustments as circumstances change (Northern Trust guidance).
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That discipline matters because “emerging technology” combines unlike exposures. A listed semiconductor company, an artificial-intelligence (AI) software fund, a direct investment in a quantum-computing start-up, a data-center project, a digital token and an energy-transition infrastructure asset can differ radically in liquidity, valuation, custody, regulation, operating risk and time to exit. They should not be treated as one asset class simply because a survey groups them under a technology theme.
The IPS should therefore answer two separate questions: what the family is trying to achieve, and what risks it is willing and able to carry while pursuing that objective. Technology forecasts can inform a decision; they should not replace the decision rules.
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Step 1: Define the policy’s purpose and scope
Start with a plain-language scope statement. Decide whether the policy covers only investment holdings or also operating-company investments, direct deals, co-investments, philanthropic vehicles and the office’s own use of AI tools. State whether “emerging technology” includes AI, digital assets, energy transition, quantum computing, advanced communications, agriculture technology and related infrastructure, or only a subset.
Questions the scope section should settle
- Which technologies, business models and use cases are included?
- Are public securities, funds, private venture investments, direct investments, infrastructure and digital assets all eligible, or are some excluded?
- Does an investment that becomes a large technology exposure through an operating company count toward the same limits?
- Does the policy apply to every family member and entity, or only to assets managed by the office?
- Are internal AI experiments governed by the IPS, a separate technology policy, or both?
Write definitions that an investment committee, administrator and auditor can apply consistently. For example, define whether a “digital-asset exposure” includes a fund holding tokens, a listed company whose value depends on token activity, or only direct custody of tokens. Ambiguity at this stage produces inconsistent reporting later.
Step 2: Assign authority, accountability and escalation
List who may originate an idea, perform diligence, approve a commitment, sign documents, monitor the position and authorize an exit. Separate duties where practical so that the person promoting a deal is not the sole reviewer of its risks.
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| Decision | Minimum policy treatment |
|---|---|
| Idea or pipeline entry | Name the responsible originator and the information required before review. |
| Initial diligence | Identify the lead reviewer, required specialist advice and conflict checks. |
| Commitment or purchase | Set the approving body, voting or consent rule, and any monetary or concentration threshold. |
| Exception to a limit | Require written rationale, named approver, expiry date and reporting to the governing body. |
| Follow-on funding | Require a fresh liquidity, valuation, governance and exposure analysis rather than automatic pro-rata approval. |
| Exit, transfer or write-down | Specify who can act, how conflicts are handled and how the decision is recorded. |
Include a succession rule for an absent or conflicted decision-maker. The policy should also state when external legal, tax, cybersecurity, technical or valuation advice is required. Governance should make decisions faster by clarifying who can say yes, who must be consulted and when an exception must be escalated. Morgan Lewis summarizes this principle as “governance enables speed” (Morgan Lewis, June 29, 2026).
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Step 3: Specify permitted routes to exposure
Route matters as much as theme. A public security can usually be sold more readily than a venture commitment; an infrastructure project may have long contracts but substantial construction and financing risk; direct digital-asset custody introduces operational controls that a fund investor may not handle itself.
| Route | Typical characteristics to address in the IPS | Questions before approval |
|---|---|---|
| Public securities | Market liquidity, price volatility, issuer concentration and trading restrictions. | What position size, rebalancing rule and liquidity assumption apply? |
| Funds | Manager selection, lock-ups, capital calls, fees, valuation policy and look-through exposure. | How are unfunded commitments and overlapping holdings counted? |
| Venture or growth investments | Illiquidity, financing needs, uncertain valuations, dilution and exit dependence. | Can the family meet follow-on calls without selling core assets? |
| Direct investments | Control rights, information access, key-person dependence and operational involvement. | Who monitors the company and exercises governance rights? |
| Infrastructure | Construction, permits, leverage, offtake or customer contracts and long asset lives. | What happens if completion, regulation or demand changes? |
| Digital assets | Custody, private-key security, liquidity fragmentation, protocol or issuer risk and changing regulation. | Who controls wallets or custodians, and how are losses, forks or service outages handled? |
State excluded forms explicitly. An exclusion can be temporary and reviewed when custody, regulation or internal capability changes.
Step 4: Set portfolio boundaries without pretending there is a universal percentage
Use family-specific target ranges or maximums, not a headline allocation copied from a survey. The IPS should define:
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- Concentration limits by issuer, manager, technology, geography, counterparty and correlated revenue driver.
- How direct holdings, fund look-through exposure, co-investments and operating-company interests are aggregated.
- How unfunded commitments and expected capital calls are counted against liquidity.
- Loss tolerance, leverage restrictions, currency exposure and acceptable valuation uncertainty.
- What happens when market movements or a new commitment breach a limit.
There is no evidence for one suitable percentage for all family offices. A family funding near-term education, philanthropy or a business succession may need substantially more liquid assets than a family with durable cash flows and a multi-decade horizon. Document the assumptions behind each limit so a later committee can distinguish a deliberate change from accidental drift.
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Step 5: Make diligence evidence-based
Require a written investment memorandum that tests both the technology and the business around it. At minimum, examine:
- What problem the product solves, for whom, and whether customers pay repeatedly.
- Revenue quality, unit economics, cash burn, financing needs and path to additional capital.
- Management capability, board oversight, incentives, key-person dependence and succession.
- Ownership of intellectual property, licenses, training data, customer data and other material rights.
- Third-party dependencies, cloud or hardware concentration, supply-chain exposure and cybersecurity.
- Regulatory status, expected rule changes, permits, cross-border restrictions and litigation.
- Valuation methodology, comparable transactions, dilution scenarios and credible exit paths.
- The office’s capacity to receive information, monitor milestones and act on deterioration.
Additional AI diligence
AI claims require evidence beyond a product demonstration. Morgan Lewis identifies data rights, governance maturity, regulatory readiness, intellectual-property ownership and model dependencies as core diligence topics. Ask what data the company may lawfully use, whether customers can withdraw or restrict data, which models and vendors are critical, how performance is tested, and what happens if a model provider changes terms or access.
Review controls for security, bias, explainability and incident response where the product affects people or regulated decisions. Confirm who is accountable for outputs and whether the company can document model changes. A technically impressive system can still be an unsuitable investment if its rights, economics or dependencies are unclear.
Step 6: Govern the office’s own use of AI
Investment risk and operational risk are related but should be documented separately. Create an internal AI schedule or cross-reference another technology policy. It should record:
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- Approved use cases and prohibited uses.
- An accountable owner for each system and a named human reviewer for consequential decisions and external communications.
- Approved vendors, access permissions, authentication, retention and audit logs.
- Rules for confidential family, portfolio, client, employee and deal information.
- Vendor terms covering data use, training, confidentiality, security and breach notification.
- Required testing, recordkeeping and escalation for inaccurate, biased, leaked or manipulated output.
Do not rely on either a blanket ban or uncontrolled consumer-tool use. Morgan Lewis advises establishing governance before broad adoption and states that “AI should augment and not replace human judgment.” Human review must be meaningful: the reviewer needs the context, authority and time to reject or correct an output.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Step 7: Add technology-specific risk schedules
Digital assets
Define eligible instruments, approved venues and custody arrangements. Set rules for private-key control, transaction authorization, address whitelisting, segregation of duties, reconciliations, insurance and recovery after a lost credential or service outage. Address liquidity windows, valuation sources, tax records, sanctions screening and the treatment of forks, airdrops, staking or protocol changes where relevant. The IPS should say who can halt transfers and how a suspected compromise is escalated.
Energy-transition and infrastructure assets
Require analysis of permits, construction milestones, grid or interconnection access, resource assumptions, offtake contracts, subsidies, leverage, insurance and decommissioning obligations. Stress-test delays, cost overruns, policy changes and lower-than-expected demand. Long asset lives make exit assumptions especially important.
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Separate scientific feasibility from commercial timing. Require independent technical review, milestone definitions, financing runway and a plan for failure. A promising research result does not establish a market, a defensible patent position or a near-term exit.
Step 8: Monitor, report and trigger reviews
Name an owner for each exposure and establish a reporting pack that covers current value, unfunded commitments, liquidity, concentration, valuation method, key milestones, covenant or limit breaches, material technology changes, regulatory developments and exceptions. Report failed milestones and stale valuations, not only favorable news.
Set review triggers rather than relying solely on a calendar. Triggers can include a material change in family liquidity or objectives, a new jurisdiction, a major regulatory action, loss of a critical model or supplier, a cybersecurity incident, a financing round at a materially different valuation, or a breach of a portfolio limit. The policy should also specify a regular review schedule chosen by the family; the available guidance supports adaptability but does not prescribe one universal interval.
What current surveys do—and do not—say
Survey data explains why many offices are formalizing policy, but it is not an allocation benchmark.
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|---|---|---|
| J.P. Morgan Private Bank, 2026 Global Family Office Report (333 offices in 30 countries) | 65% planned to prioritize AI; more than half had no venture or growth-market exposure; 79% reported no infrastructure allocation. | Interest and actual exposure can diverge; the figures do not prescribe a target. Read the report. |
| UBS Global Family Office Report 2026 (307 offices across more than 30 markets) | 65% were invested somewhere across the AI value chain, including data-center infrastructure, software platforms and semiconductor producers. | This measures existing investment, unlike the J.P. Morgan measure of planned priority; the samples and definitions differ. Read the report. |
| UBS Global Family Office Report 2025 | 27% reported a clear generative-AI investment strategy and 27% a clear energy-transition strategy; respondents also wanted more information on blockchain/DeFi, 6G, quantum computing and agriculture or sustainable living. | Many offices are interested without having a documented strategy. Read the report. |
Legal and jurisdictional checks
Legal treatment depends on the office’s structure, activities and jurisdiction. In the United States, SEC staff responses about the family-office rule expressly state that they are staff views, not a rule, regulation or statement approved by the Commission (SEC staff responses, updated March 23, 2018). Confirm the current law for every relevant entity and obtain qualified legal, tax and regulatory advice before relying on an exemption, marketing a fund, trading digital assets or sharing information across borders.
Quick Recap
A practical IPS implementation sequence
- Document family objectives, liquidity needs, time horizon, risk capacity, jurisdictions and decision-makers.
- Inventory current and proposed technology exposures, including indirect and operating-company holdings.
- Choose permitted routes and write aggregation, concentration, liquidity and exception rules.
- Adopt the approval matrix and diligence checklist, with specialist-review requirements.
- Add AI-use controls and technology-specific schedules for digital assets, infrastructure and other high-dependency exposures.
- Assign monitoring owners, reporting fields, escalation contacts and review triggers.
- Obtain legal and tax review, approve the IPS through the family’s governing process, and train everyone who can originate, approve or operate an investment.
- Record each exception and update the policy when family circumstances, law, technology or portfolio structure materially changes.
Pre-approval checklist
- Does the proposal fit a stated family objective and permitted technology definition?
- Is the route to exposure, liquidity, valuation method and exit path understood?
- Are data, IP, regulatory, cybersecurity and third-party dependencies documented?
- Can the family meet capital calls and absorb a total loss without impairing essential commitments?
- Has an independent or appropriately qualified reviewer tested the central assumptions?
- Is the decision within limits, or is a dated, documented exception approved?
- Is someone accountable for monitoring and for acting when a trigger occurs?
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