Practice chapter
By Niko Hatziiosifidis · last reviewed 23 Aug 2026
In Germany you can buy an ELTIF by four routes: through your own bank with advice, through ELTIF-capable fund platforms, through neobrokers, or directly from the provider. Since September 2025 Trade Republic has offered two ELTIFs (Apollo, EQT) from €1 including a savings plan, and Scalable Capital a BlackRock ELTIF from €10,000 (as at July 2026). On every route the MiFID II suitability assessment is mandatory — pure execution-only without an assessment is not permitted, according to BaFin. Subscriptions are usually taken at monthly dates, at a NAV that is only struck afterwards; several weeks can pass before the shares are booked into your custody account.
Of the 268 ELTIFs registered in Europe, holding €34.0 billion between them (198 with reported assets, up 54.7% on the year), around three quarters are open to retail investors — but you can buy any given fund only where it has actually been made available. Four distribution channels have become established in Germany.
Route 1: your own bank or an adviser. Traditional branch and private banks distribute ELTIFs through advised sales. HypoVereinsbank, for instance, offers ELTIFs from €10,000, among them the Partners Group Private Equity Evergreen and the BlackRock Multi Alternatives Growth Fund (accessed: August 2026). The sequence: advice appointment, suitability assessment, subscription form. On costs, this is where the full entry charge typically is payable — klimaVest from Commerz Real, for example, discloses up to 5% (as at 31 July 2026).
Route 2: fund platforms. Platforms such as FondsSuperMarkt place ELTIFs with a the entry charge waived; settlement runs through Fondsdepot Bank, because by no means every custodian bank can hold ELTIFs at all. Six ELTIFs were connected most recently (among them klimaVest, Partners Group, Swiss Life Privado Infrastructure), with minimum investments from €50 up to €10,000 depending on the fund; savings plans are not possible for settlement reasons (accessed: August 2026).
Route 3: neobrokers — details in the next section.
Route 4: direct distribution and digital providers. Some providers let you subscribe with no bank in between: Commerz Real offers fully digital direct subscription for klimaVest, and Moonfare has offered a private equity ELTIF from €10,000 through its app since July 2024, with around 50 portfolio companies and a digital secondary market after a two-year holding period (source: Das Investment, 9 July 2024). On every route ELTIFs are held in your custody account like an ordinary security with an ISIN/WKN — klimaVest, for instance, under LU2183939003 / KLV100; Fondsdepot Bank keeps them in separate sub-accounts.
Trade Republic launched its private-markets offering on 15 September 2025 with Apollo and EQT as partners, investable from €1 in fractional shares (press release). The two funds are the Apollo Global Private Markets ELTIF (LU3170240538, ongoing costs 2.80% p.a. plus a performance fee) and the EQT Nexus ELTIF (LU3176111881, 2.35% p.a.); both are available through savings plans (Finanztip, 18 September 2025). Important for putting this in context: the monthly “sale” runs through an internal marketplace and requires a counterparty — Trade Republic can decline to execute it; the regular redemption through the fund happens quarterly, and the gates differ from fund to fund: 5% of net asset value per redemption date for the Apollo fund, 3% of whole-fund NAV for EQT Nexus — measured as net redemptions after subscriptions in the same quarter and temporarily reducible to 1.5% (PRIIPs KIDs and prospectuses of the two funds, compiled in our fund database).
Scalable Capital offers the BlackRock Private Equity Fund (LU2970811951): a single investment from €10,000, monthly NAV determination and subscription, no redemptions until 30 June 2027 and quarterly thereafter with a gate of 5% of net fund assets per quarter, additionally capped at 27.3% of the fund’s liquid assets (accessed: August 2026). There is no entry charge. The PRIIPs KID for class C1 Accu EUR (6 May 2026) shows 2.20% management and operating costs plus 0.10% transaction costs, together with a performance fee of up to 12.50% of total net returns above a 5% preferred return with a high-water mark — a cost impact of 1.62% p.a. on a five-year average. Scalable does not show a savings plan on its product page, which left Trade Republic as the only neobroker whose ELTIF offering could be bought through a savings plan (as at August 2026).
No. Article 30 of the ELTIF Regulation as amended by Regulation (EU) 2023/606 (“ELTIF 2.0”, applicable since 10 January 2024) requires a suitability assessment under Article 25(2) of the MiFID II Directive before any distribution to retail investors — and does so regardless of the distribution channel, including a purchase made directly from the provider or through a secondary market (Norton Rose Fulbright). In return, the old €10,000 minimum investment and the 10% portfolio cap have been scrapped. You are asked about your knowledge and experience, your financial situation including your ability to bear losses, and your investment objectives, investment horizon and risk tolerance.
A “waiver of advice” changes nothing about that: in its FAQ on the ELTIF Regulation, BaFin makes clear that pure execution-only without an assessment is not permitted — though conversely the suitability assessment does “not mean that investment advice must necessarily go with it”. Neobrokers therefore implement it as a digital questionnaire. If the result is negative, the regulation lets you subscribe anyway only with your express consent; for ELTIFs with a term of more than ten years a written warning is prescribed on top (Regulation 2023/606). Incidentally, financial investment brokers licensed under § 34f GewO may also distribute ELTIFs (BaFin FAQ).
Unlike an ETF, there is no real-time exchange price. You buy at the net asset value (NAV), which is only struck after your order (“forward pricing”). Many ELTIFs have only monthly subscription dates, at month end for instance; the subscription date is preceded by a statutory two-week withdrawal period, during which you can pull out of the purchase order free of charge. Settlement and booking into the custody account follow only once the management company has confirmed — which can take several weeks (Fondsdepot Bank, accessed: August 2026). The Erste Private Markets Evergreen ELTIF, to take another example, likewise accepts subscriptions monthly and redemptions as a rule quarterly (Erste AM, accessed: August 2026); klimaVest is the exception, calculating its NAV on every business day (as at 31 July 2026). Fractional shares and savings plans are in practice available only at neobrokers — through Fondsdepot Bank, savings and withdrawal plans for ELTIFs are expressly not provided for. In our database (141 semi-liquid funds) quarterly redemption is the standard, at 93 of 141 funds, and the gate is usually 5%.
The product costs (management fee, performance fee) are set out in the PRIIPs KID and fall due everywhere — the distribution channel decides what comes on top. The first metric is the entry charge: up to 5% for klimaVest in traditional distribution (as at 31 July 2026), discounted by 100% on platforms such as FondsSuperMarkt, and dropped entirely at Scalable Capital (sources as above). The second metric is the exit costs and the liquidity mechanics of the route in question (internal marketplace versus redemption at NAV). Third point: the remuneration model. Commission-based distribution is permitted in Germany; fee-based investment advisers, by contrast, may be paid only by the client and must pass on unavoidable inducements “in full to the client” (§ 64(5) WpHG).
In Austria, yes — the ELTIF has an EU distribution passport, and what matters is whether the particular fund has been notified for distribution in that country. Erste Asset Management has a product of its own, the Erste Private Markets Evergreen ELTIF (LU3284407171), from €10,000 “depending on the institution” (accessed: August 2026). In Switzerland the EU passport does not apply: foreign funds may be offered to non-qualified investors only with FINMA authorisation, including a Swiss representative and paying agent; without that authorisation the offer stays reserved for qualified investors. Our database sets out the distribution countries for each fund wherever they are documented.
The cost cascade of the distribution channel. For the total-cost view of a mandate, what counts is the cascade of (1) entry costs (entry charge 0–5%, discounted depending on the channel), (2) ongoing product costs including the performance component — the range across the current retail ELTIFs runs from a 1.4% management fee plus a 15% performance fee (Erste AM) to 2.80% p.a. plus 12.5% above a 5% hurdle (Apollo via Trade Republic; PRIIPs KID) — and (3) the exit costs of the channel. Point 3 in particular is channel-dependent: the monthly marketplace sale at Trade Republic is not a redemption at NAV but a matching transaction that the broker can decline (Finanztip, 18 September 2025) — so the suitability documentation should carry the fund’s redemption mechanics (quarterly, gate) as the governing liquidity assumption, not the marketplace promise.
Inducements and rebates. Commission-based distribution of ELTIFs is permitted in Germany, including through brokers licensed under § 34f GewO (BaFin FAQ; Pfefferminzia). In fee-based advice, § 64(5) WpHG bites: no monetary inducements, and unavoidable ones must be passed on without delay and in full, and disclosed. Platform discounts on the entry charge, by contrast, are a price reduction for the client, not an inducement to the intermediary — to be kept cleanly apart in the ex-ante cost disclosure.
Subscription-form pitfalls. First, the timeline: a statutory two-week withdrawal period before the — often only monthly — subscription date, settlement only once the management company has confirmed, booking sometimes weeks later (Fondsdepot Bank); the settlement NAV is unknown when the order is placed. Second, the ancillary duties under Article 30 of the ELTIF Regulation: express, documented consent where the suitability result is negative, and a written warning for terms of more than ten years — both belong on file in audit-proof form. Third, the settlement limits: no savings or withdrawal plans through classic fund-platform settlement, and custody in some cases in sub-accounts, which affects reporting and transferability. In July 2026 FONDS professionell had lawyers assess the distribution requirements: the criteria for legally sound advice and intermediation were “essentially the same as for other structured real-asset investments”, but a few aspects deserved particular attention (“ELTIF-Vertrieb: Anwälte warnen vor Haftungsfallen”, 14 July 2026) — in essence: avoid the illusion of liquidity, assess suitability substantively, keep the documentation complete.
Yes. Since 15 September 2025 Trade Republic has offered the Apollo Global Private Markets ELTIF and the EQT Nexus ELTIF from €1, and Scalable Capital the BlackRock Private Equity Fund from €10,000 (as at July 2026).
In part. At Trade Republic both ELTIFs are available through savings plans (Finanztip, 9/2025); at Scalable a savings plan was “in planning” in July 2026, and through fund platforms settled by Fondsdepot Bank, ELTIF savings plans are not possible.
In Germany: branch and private banks in their advice business (HypoVereinsbank, for example, offers ELTIFs from €10,000), alongside fund platforms with an ELTIF-capable custodian bank, neobrokers and the providers’ own direct distribution. Which fund is available where is decided by the connection in each case.
Yes — but not without a suitability assessment. Article 30 of the ELTIF Regulation prescribes it on every distribution channel; pure execution-only is not permitted, according to BaFin. If the assessment comes out negative, the subscription can go ahead only with your express consent.
It depends on the route: an entry charge of up to 5% in bank distribution (klimaVest is one example), a 100% discount on that at platforms such as FondsSuperMarkt, and no entry charge at Scalable. The ongoing fund costs (currently approx. 1.4–2.8% p.a. plus a performance fee) fall due on every route.
Often several weeks: a two-week withdrawal period runs before the usually monthly subscription date, settlement is at the NAV then struck, and booking follows only once the management company has confirmed (Fondsdepot Bank, as at 8/2026).
Last reviewed: 23 Aug 2026 · Methodology · Not investment advice.