Germany’s Altersvorsorgedepot will create new openings for investment managers, but the opportunity will not be distributed evenly. Domestic captive managers are well positioned in the branch channel, leaving cross-border firms to compete primarily through digital platforms, self-directed investors, and independent advisers.

For a fuller analysis of the reform, including the size and shape of the opportunity, read our overview of the five questions asset managers should be asking about the AVD.

How can cross-border managers win a seat at the table? There are four areas to focus your attention now in order to take advantage of new opportunities in Germany.

1. Get operationally eligible

Before a platform will list your fund, and before an adviser can recommend it, the basics have to be in place:

• German-language documentation: Key Information Documents (KIDs) and factsheets in German are mandatory, not optional.
• Current BaFin notification: Notification with the German regulator, BaFin, must be up to date for the relevant share classes.
• The right settlement route: The fund must settle via Clearstream Frankfurt or Euroclear to pass platform onboarding screens.
• German tax reporting: Reporting through a recognised tax reporter (Steuervertreter) is needed for funds to qualify for the partial exemption under Germany’s final withholding tax (Abgeltungsteuer). Without it, your fund is tax-disadvantaged against domestic alternatives at exactly the moment a saver is comparing them.

The good news? These are not new requirements. They are the same foundations that have always applied to cross-border distribution in Germany. If you already distribute there, this is a health check. If you don’t, it is the first item on the project plan.

2. Make your fund Sparplan-ready on digital platforms

A Sparplan is a German regular savings plan. It is how AVD money will actually move. A fund that can’t be included in a monthly savings plan is functionally invisible in the AVD context. For most savers, contributions are likely to flow through regular direct debits rather than one-off lump-sum purchases.

This matters most on the digital platforms. Neobrokers are positioned to capture the digitally active, cost-sensitive saver. Their default flows will be overwhelmingly passive, but these platforms have no captive product shelves of their own. Alongside their Standarddepot defaults, they will offer open fund catalogues. That is where an active, multi-asset, or specialist fund can find its way in front of savers.

Getting there may take more than a technical listing. Expect it to require a conversation with the platform’s partnership team. And because platforms are finalising their launch catalogues now, that conversation is time-sensitive.

3. Offer a clean share class for the advised channel

Germany’s fee-only advisers, the Honorarberater, are legally prohibited from earning product commissions. That makes them structurally more independent than bank-tied consultants, and it makes them a natural channel for higher-net-worth savers who specifically want an alternative to the bank-branch default.

It also sets a hard rule for managers. An Honorarberater will not recommend a fund that pays trailer fees, because doing so would breach their obligation to act independently. To compete in this channel, you need a clean or Z share class with:

• Institutional pricing
• No front-end load
• No retrocession

If you currently offer only A-class retail shares into Germany, this is a gap to close before January 2027.

4. Put a German-speaking distribution contact on the ground

There is no substitute for a native German speaker with relationships across the Honorarberater community, the digital platform partnership teams, and the regional IFA networks. These are the three doors into the open segments of the AVD, and each one runs on relationships.

Pan-European coverage from London or elsewhere, where Germany is one of seven markets on the same person’s territory, might not generate the depth of relationship this market requires. Steps one to three get your fund through the door. Step four is what gets it chosen.

The window is narrow

Germany’s pension reform is a genuine structural shift, the kind that happens once in a generation.

Platforms are finalising their launch catalogues, and partnership conversations need to happen now. Share class structures need to be reviewed, and German documentation needs to be completed sooner rather than later. Now is the time to assess your firm’s readiness for distribution in Germany and seek guidance from distribution experts.