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Beyond the Mark: Making Private Equity Valuations Defensible - S&P Global

Reported by Spglobal
Aug 25, 2026· 2 min read
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Key Takeaways
  • • Private equity valuations are increasingly subject to regulatory, auditor, and investor scrutiny, requiring institutions to document not just the valuation number but the evidence, judgment, and governance supporting it.
  • • Level 3 assets like private equity investments lack readily observable market prices, making defensibility of methodology and assumptions more critical than the valuation figure itself.
  • • Effective private equity valuation rests on two pillars: a clear valuation framework with documented methodologies and assumptions, and robust governance including independent review and challenge by valuation committees and boards.
  • • Market volatility, extended holding periods, and limited exit activity are eroding confidence in traditional valuation assumptions, forcing institutions to strengthen the transparency and consistency of their judgment-based valuations.
Summary
Private equity valuations face mounting pressure from regulators, auditors, and institutional investors demanding greater transparency and defensibility of valuation judgments. This shift reflects broader market conditions—including volatility, longer investment holding periods, and constrained exit activity—that make historical valuation assumptions increasingly difficult to sustain. Rather than producing isolated valuation figures, institutions must now construct a comprehensive narrative that explains the methodologies, assumptions, evidence, and governance underpinning their valuations.

The challenge is particularly acute because private equity investments are classified as Level 3 assets under fair value accounting frameworks, meaning they lack readily observable market prices. Unlike publicly traded securities, private equity valuations cannot rely on market-derived benchmarks and instead depend heavily on professional judgment. The objective, according to S&P Global's analysis, is not to eliminate judgment but to make it visible, structured, consistently applied, and subject to independent review. This requires institutions to establish clear valuation frameworks supported by relevant market and company evidence, coupled with robust governance processes that include independent challenge and documentation.

Two foundational elements distinguish defensible from indefensible private equity valuations. First, a well-articulated valuation framework must specify methodologies, outline assumptions, and document the professional judgments underlying each valuation decision. Second, governance structures—including valuation committees, board oversight, and control functions—must provide independent review and challenge of these assumptions. Together, these elements transform private equity valuation from a mechanical exercise into a disciplined, auditable process capable of withstanding scrutiny from regulators and institutional stakeholders. As the private markets continue to grow in complexity and institutional capital allocation, this rigor has become essential for maintaining investor confidence and regulatory compliance.

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Spglobal Beyond the Mark: Making Private Equity Valuations Defensible - S&P Global