The Altersvorsorgedepot under fire: what consumer advocates criticize – and what speaks against it

The key points at a glance

• The statutory cost cap applies only to the default standard product, not to all certified offerings on the market.
• Consumer advocates consider even the capped cost rate too high, measured against low-cost index ETFs.
• The wide choice of products and providers can overwhelm beginners who are looking for a simple, low-cost offering.
• With guarantee products in particular, after costs and inflation there is sometimes barely more left than the government allowance.
• Many of these drawbacks can be avoided by choosing your provider deliberately. That is exactly where an independent comparison helps.

Criticism 1: the cost cap is too high – and does not apply to everything

What consumer advocates say. For the default standard product, lawmakers prescribe an upper limit on costs. That is progress, but Britta Langenberg of Finanzwende and the vzbv consider the limit set too high. Their argument: anyone familiar with broadly diversified index ETFs knows that annual costs well below 0.5 percent are possible. The vzbv illustrated the effect with a sample calculation. A low-cost default standard product with costs of around 0.2 percent could produce roughly €180,000 in asset growth after 40 years on a monthly contribution of €130, while a more expensive product would deliver only around €80,000. The difference ends up with the providers, not with the saver.

On top of that, the cap applies only to the default standard product. Alongside it, further certified products may be sold that it does not cover.

What speaks against this. For the first time ever, a subsidized retirement product comes with a statutory cost cap. That is more consumer protection than the old Riester pension offered. Above all, though, the cap is an upper limit, not a target. Cost-conscious providers, neobrokers in particular, will offer their securities accounts well below it in order to compete. If you choose a low-cost provider yourself, you will end up paying a fraction of the permitted maximum costs.

In short: The criticism is justified, because the cap is high and does not apply everywhere. But you are not at its mercy. The decisive lever remains the choice of a low-cost provider.

Criticism 2: too much choice overwhelms beginners

What consumer advocates say. Instead of one clear, simple offering, 2027 will bring numerous standard securities accounts, guarantee products and insurance solutions onto the market at the same time. The vzbv warns that precisely those people who are looking for a simple and low-cost product will lose track in the abundance. The concern goes further: the low-cost default standard product could serve merely as a door opener in the sales conversation, so that products paying higher commissions can then be recommended.

What speaks against this. Variety also has a good side: it is the basis for competition and therefore for falling prices. And the sense of being overwhelmed can be resolved. That is exactly what independent comparison services are for, classifying products by clear criteria such as costs, ETF selection and flexibility. With a pre-selection behind you, you do not have to fight your way through the entire market but can go straight to the few products that are worth considering for you.

In short: The abundance of products is real and can be unsettling. A neutral comparison and a clear look at the costs take much of the sting out of this criticism.

Criticism 3: with guarantee products, little is often left

What consumer advocates say. Many people reach for products with a full or partial contribution guarantee out of a need for security. Consumer advocates and many experts warn against this, because the guarantee limits the possible equity allocation and causes additional costs. After costs and inflation, what is left at the end is sometimes barely more than the government subsidy you would have received anyway.

What speaks against this. No one has to choose a guarantee product. The Altersvorsorgedepot expressly also allows investing with no guarantee at all, with a full ETF allocation and the corresponding return potential. If you have a long investment horizon of 15 years or more, you can sit out fluctuations and usually do not need the expensive protection. The guarantee is an option for very security-minded savers or for people shortly before retirement, not an obligation.

In short: The warning about expensive guarantee products is justified. But it concerns only one of several product variants. If you know the alternatives, you decide deliberately instead of by reflex.

The central demand: a single default standard product

Beyond the individual points, the vzbv has one fundamental demand: instead of many different standard securities accounts, there should be a single public-sector default standard product, similar to the state fund AP7 in Sweden. It should work without sales commissions, be easy to understand and, through broad investment in the capital market, deliver good returns at very low cost.

Lawmakers did not take this route and are relying instead on competition among many providers. Whether that ends up being just as cheap for consumers as a single state solution will become clear once the first terms are known. Until then, one thing holds: comparing is all the more worthwhile.