Incentive As
Incentive As is an SEC-registered investment adviser based in Oslo, Norway that reports managing 4 hedge funds on Form ADV. It reports $2.5 billion in regulatory assets under management. Its private funds, of all types, hold $1.7 billion in gross assets. Its disclosed U.S. stock holdings returned an estimated -26.7% 2025 YTD through Dec 31 (S&P 500: +16.4%), based on 13F filings. Over a longer period they returned an estimated -42.6% from Q3 2024 to Q4 2025, compared with +25.3% for the S&P 500, based on 13F filings.
- Regulatory assets under management
- $2.5 billionForm ADV Item 5.F
- Gross assets of private funds
- $1.7 billionAll private fund types, Form ADV
- Hedge funds managed
- 44 private funds in total
- Employees
- 6Form ADV Item 5.A
- Registration
- SEC-registered adviserCRD 174704
- Latest Form ADV
- 05/22/2026Disciplinary disclosures: none reported
Estimated 13F portfolio performance
| Quarter | Est. 13F return | S&P 500 |
|---|---|---|
| Q4 2025 | -9.2% | +2.4% |
| Q3 2025 | -1.3% | +7.8% |
| Q2 2025 | +1.6% | +10.4% |
| Q1 2025 | -19.5% | -4.5% |
| Q4 2024 | -3.2% | +2.1% |
| Q3 2024 | -19.1% | +5.4% |
Estimate of the firm's disclosed long U.S. stock portfolio from its quarterly 13F filings, holding each quarter-end portfolio to the next quarter-end at prices implied by all 13F filers. It is a price return before dividends and fees, ignores shorts, options, bonds, cash and trading within the quarter, and is not the return of any fund. Disclosures
Largest disclosed holdings
- Smurfit Westrock PLC$71.3 million
As of 2025-12-31, from 13F filing by Incentive AS.
From SEC filings. Firm data comes from the SEC's Form ADV data as of Oct 2, 2026; performance estimates come from Form 13F. HedgeMountain has not verified this information, and it is not an offer, solicitation or recommendation. Full disclosures