The biggest AI companies mostly don't file Form D. Their SPVs do.
Form D is a notice, not a disclosure. Raises that rely only on Section 4(a)(2), without the Rule 506 safe harbor, carry no federal filing requirement, and research on about 40,000 VC rounds found most were not accompanied by a Form D. So we checked well-known SF AI companies against EDGAR one by one.
uv run python -m pipeline.verify_edgarWhich companies are visible, and which only through their SPVs?
"No Form D as a company" means no EDGAR registrant whose name starts with the company's name has filed one; a company filing under an unrelated legal name would be missed, so treat each "no" as a prompt to check, not proof. Companies that do file often file once for a round that, by announcements, was far larger or one of several. Perplexity and Replit each show one small filing. Controls (Figma, Notion, Vercel, Ramp) are not AI and are left out of the counts.
What this means for every chart on this site
- Totals are a floor. The largest AI rounds of 2023–2026 are mostly absent, so AI dollar shares understate AI's real weight, and the gap is largest at the top.
- Trends beat levels. Filing behaviour changes slowly, so quarter-over-quarter movement is more reliable than any single total.
- SPV filings are a demand signal. When dozens of vehicles form to buy one company's shares, that company is raising (or its shareholders are selling), even if it never files.
- Early-stage coverage is weakest. SAFE rounds are often filed late, once, or not at all, so seed counts are the least complete.
Sources: Hanley & Yu, The Case of the Missing Form D (ECGI); Tucker Ellis on 4(a)(2); Latham on what Form D omits.