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# Making Private Markets Valuations Defensible: From Source to Final Mark

Discover how private market teams can build traceable, reproducible, audit-ready valuations with stronger evidence, clear approvals, and reliable data.

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[What We Are Seeing](#what-we-are-seeing)[What a Valuation Challenge Requires](#what-a-valuation-challenge-requires)[Four Foundations of a Defensible Valuation](#four-foundations-of-a-defensible-valuation)[What Counts as Evidence?](#what-counts-as-evidence)[Keep Judgment Visible](#keep-judgment-visible)[Managing Changes and Legacy Valuations](#managing-changes-and-legacy-valuations)[Building Traceability Into the Process](#building-traceability-into-the-process)[Where 73 Intelligence Fits](#where-73-intelligence-fits)

Published

27 October 2026

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Pick any figure from last quarter's valuations. Find the original document, verify the number, trace the calculations, explain the assumptions, identify who approved it, and reproduce the result using the information available at the time.  
  
How long would that take?  
  
For most private market teams, longer than the person asking is willing to wait. Auditors, investment committees, limited partners (LPs), and regulators increasingly expect clear, accessible evidence to support valuations.  
  
Yet that evidence is often scattered across spreadsheets, emails, shared drives, and individual knowledge. As portfolios grow and scrutiny intensifies, reconstructing a defensible audit trail becomes increasingly difficult.  
  
The fundamental problem is that traceability is treated as a reporting task rather than built into how data, calculations, decisions, and approvals are captured.

## What We Are Seeing

In one week of conversations with customers, prospects, and partners, 17 organizations raised variations of this issue. They included private equity and private credit managers, venture investors, an insurer, and sovereign-linked investors.

Examples included:

-   A sovereign-linked investor preparing audited disclosures said auditors consistently request original source documents and wants downloadable calculations that reviewers can independently reproduce.
-   A credit manager manually uploads financial information for dozens of portfolio companies to its auditor's portal because the auditor lacks direct, read-only access to the underlying work.
-   An insurer's pricing and valuation committee chair said the drivers of quarter-over-quarter valuation changes were unclear, while regulatory scrutiny was increasing.
-   A venture investor described its valuation spreadsheet as unauditable.
-   A portfolio analytics team struggled to trace metrics through five or six calculation layers and thousands of formulas.

These conversations are not a representative survey, but they point to a consistent need: reviewers want to understand and independently verify the evidence behind a number without lengthy investigations.  
  
That need aligns with the frameworks that govern fair value. ASC 820 and IFRS 13 require fair value measurements to rest on documented inputs and assumptions, with additional disclosure for significant unobservable (Level 3) inputs, and the IPEV Valuation Guidelines expect valuation processes to be documented and consistently applied. Managers should confirm which standards, and regulatory expectations apply to their funds.

## What a Valuation Challenge Requires

A valuation challenge typically comes down to six questions:

1.  **Source:** Which original financial statement, compliance certificate, board presentation, or third-party record supports the input?
2.  **Reconciliation:** Does the model match the source, including the correct entity, reporting period, and distinction between reported and adjusted figures?
3.  **Calculation:** How did EBITDA, valuation multiples, enterprise value, net debt, and the equity bridge produce the final mark?
4.  **Assumptions:** Why were particular multiples, discount rates, or comparable companies selected? What changed from the previous quarter, and why?
5.  **Approval:** Who prepared, reviewed, and approved the specific valuation version before net asset value (NAV) was finalized?
6.  **Reproducibility:** Can the calculation be rerun using the inputs and methodology available on the valuation date to produce the same result?

Consider a portfolio company whose valuation is challenged after a material quarterly change. The adjusted EBITDA reconciliation exists only in a former analyst's working file, the compliance certificate is buried in an inbox, the rationale for the comparable company set is undocumented, and approval emails do not establish which version was final.

Reconstructing the valuation can consume two to three weeks of senior analyst time, alongside repeated exchanges with the company and auditor.

Linking source documents to individual inputs, documenting adjustments, governing model inputs, and tying approvals to locked valuation versions would make the evidence readily accessible. The objective is simple: the evidence pack should emerge from the valuation process, not be reconstructed after a challenge.

## Four Foundations of a Defensible Valuation

1.  **Source traceability:** Every material input should link to its original source, including the relevant document, page, table, or data record. Reviewers should be able to identify exactly where each figure originated.
2.  **Calculation lineage:** Reviewers must be able to trace the final mark through its inputs, formulas, methodology, and versions. Lineage breaks when values are copied, re-entered, or overridden without explanation.
3.  **Approval history:** Records should identify who prepared, reviewed, changed, and approved the valuation, and when. Approval must relate to the specific version reviewed, not simply to a position or workflow.
4.  **Reproducibility:** Given the same inputs, assumptions, and methodology version, a calculation should produce the same result. Deterministic calculations, version control, and complete lineage make this possible.

Reproducing a mark also depends on preserving point-in-time data. Market prices, comparable company multiples, FX rates, and management accounts change after the valuation date, and later restatements can alter source figures. Snapshots of the inputs actually used, with their retrieval dates, are needed to rerun the valuation as it was approved, not as it would look today.

Supporting controls include data quality checks, timestamped versions, access permissions, change logs, and consistent reporting periods. Together, they help establish what information was available at the valuation date, whether inputs were properly checked, and how changes affected reported results.

Traceability makes a valuation examinable. It does not automatically make it correct.

### What Counts as Evidence?

Evidence packs remain valuable, but reviewers may need more than a collection of documents.

-   **Evidence packs** provide portable supporting documents and explanations, provided the contents are complete and clearly linked to the valuation.
-   **Downloadable calculations with live formulas** allow reviewers to inspect the logic and independently reperform the work.
-   **Read-only system access** enables authorized reviewers to trace evidence without repeatedly requesting individual files.
-   **Screenshots** provide context but are weak as primary evidence because they cannot establish calculation reproducibility or completeness.

System-generated, timestamped records that protect against undocumented changes can strengthen the audit trail. Requirements vary by audit firm, jurisdiction, and engagement, so managers should confirm expectations early. Providing both portable evidence packs and controlled, read-only access can accommodate different review needs.

As a rule of thumb, evidence is strongest when reviewers can verify it independently. System-generated records and calculations that can be independently reproduced provide stronger evidence than static evidence packs, which in turn are stronger than screenshots or emailed explanations. The goal is for reviewers to reproduce the same result independently, rather than rely on the preparer's word.

### Keep Judgment Visible

Automation can improve data capture, reconciliation, calculation mechanics, and anomaly detection. It cannot replace human judgment when selecting comparable companies, choosing valuation approaches, normalizing earnings, setting discount rates, or assessing company-specific risks.

When an analyst changes a valuation multiple because a portfolio company faces covenant stress, the record should capture:

-   **What changed:** Original and revised values.
-   **Why:** The rationale for the decision.
-   **Evidence:** Supporting market data, management commentary, or third-party analysis.
-   **Who and when:** The author, reviewer, and timestamps.
-   **Scope and review:** Affected periods and positions, whether the change is expected to persist, and the conditions that should trigger reconsideration.

An unexplained override may look like an error. An override supported by evidence, documented reasoning, and approval demonstrates considered judgment.

## Managing Changes and Legacy Valuations

Restated financials and methodology changes must not silently overwrite historical records.

For restated inputs, retain the original and revised values, the restatement date, and the reason. Reassess affected valuations through a controlled process and document the NAV impact.

For methodology changes, record the rationale and approval against the relevant valuation date. Where practical, recalculate prior-period valuations under both methodologies to distinguish changes in approach from changes in portfolio performance.

Legacy valuations require a risk-based approach. Prioritize reconstruction according to materiality, position age, and the likelihood of a future challenge or exit. Use primary sources where available, clearly distinguish recovered evidence from assumptions, and document areas of uncertainty. Establish a defined date from which complete lineage capture becomes standard.

## Building Traceability Into the Process

Traceability depends on sound data structures and disciplined workflows, not reporting tools alone.

Entities, periods, and metric definitions need stable identifiers. Extracted values must remain linked to their source documents and relevant locations. Where AI supports extraction, confidence indicators should flag values requiring human review.

Calculations should be deterministic, with inputs, formulas, and methodology versions preserved. Data quality checks should identify missing information, inconsistent periods, and unexpected movements. Access controls and change logs should establish who can modify critical inputs and what changed.

Most importantly, evidence must remain connected throughout the workflow, from the original source document to the extracted value, calculation, assumptions, final mark, review, and approval.

### Where 73 Intelligence Fits

[**73 Intelligence**](/platform/) connects portfolio data, continuous monitoring, and audit-ready valuations across the investment lifecycle.

-   [**73 Extract**](/solutions/extract/) converts unstructured portfolio documents into structured, labeled data, keeping extracted values linked to their sources through confidence scoring and traceability.
-   [**73 Monitor**](/solutions/monitor/) uses AI-powered insights built on structured, governed data to provide real-time portfolio visibility, detect anomalies, and explain what changed and why.
-   [**73 Value**](/solutions/value/) transforms trusted data into deterministic, audit-ready valuations, connecting inputs, calculations, methodologies, assumptions, approvals, and version history.

Together, **73 Extract**, **73 Monitor**, and **73 Value** connect portfolio performance to defensible valuation decisions, giving teams less time chasing evidence and more time making decisions.

See how **73 Intelligence** makes valuations transparent, auditable, and repeatable.

[Book a demo to learn more.](https://hubs.li/Q04C8fmf0)