Altersvorsorgedepot: which rules only take effect from 2028?

Tilman Freyenhagen

Published on 24 July 2026 · Managing Director & Partner, Alsterspree Verlag GmbH

The reform timeline: why some rules only take effect in 2028

The Altersvorsorgedepot (AVD, the new state-subsidised retirement investment account) officially launches for investors on 1 January 2027, but the law provides for staggered commencement: individual core rules from Articles 3, 4, 7 and 10 of the Altersvorsorgereformgesetz (the pension reform law) only take effect on 1 January 2028^[1]. This time split mainly concerns complex downstream processes such as revised procedures for payout phases, deferred taxation rules and interfaces within the tax administration. For savers who sign a new contract in 2027, the 2027 start of state support is unaffected; the systematic transition in the administrative background, however, happens in two defined steps.

The statutory timeline at a glance: 2027 vs. 2028

• 1 January 2027 (start of the accumulation phase): enables new Altersvorsorgedepot contracts, the start of contributions, the full state Grundzulage and Kinderzulage (the child allowance), and tax-free investment returns during the accumulation phase.
• 1 January 2028 (Articles 3, 4, 7 and 10 take effect): technical adjustments to payout phases, revisions to the Einkommensteuergesetz (Income Tax Act), and the final reporting procedures for existing Altersvorsorge contracts come into force.

This two-step structure between signing the contract and the follow-up administration lets financial services providers and investors start building capital without delay on 1 January 2027. At the same time, IT infrastructure and authorities get the lead time they need for later payout phases. Savers therefore need not fear any loss of state support in 2027, but should factor in the specifications for payouts and transfers of existing entitlements that apply from 2028.

Article 3 of the AVRG: which changes to the Einkommensteuergesetz apply from 2028

While the basic support structures of the Altersvorsorgedepot already take effect on 1 January 2027, Article 3 of the Altersvorsorgereformgesetz (AVRG, the pension reform law) only takes effect on 1 January 2028^[2]. This article governs the systematic follow-on changes to the Einkommensteuergesetz (EStG, Income Tax Act). The rule is designed to permanently secure the tax treatment of subsidised retirement provision and to create clear rules for transitional cases. For investors, this mainly concerns the interplay between the Sonderausgabenabzug (deduction as a special expense) and the mechanisms of deferred taxation.

Clarifying § 52 EStG and defining the transitional phase

A central part of Article 3 is the adjustment of the application provisions in § 52 EStG. Here the legislature sets out precisely how to treat contracts that were concluded before 1 January 2028^[3], or whose payout phase begins before that date. This prevents retroactive tax disadvantages for existing contracts and avoids uncertainty in the tax treatment of returns.

• Clarifying § 52 EStG: sets out that the law in force until the end of 2027 continues to apply to reduction and dissolution amounts from Altersvorsorge contracts whose payout phase begins before 2028.
• Permanent design of the Sonderausgabenabzug: harmonises the tax deductibility of own contributions with the new allowance structure.
• Tax treatment of returns: clarifies that capital gains and dividends within the Altersvorsorgedepot remain completely tax-free even during the transitional phase, and are only taxed on a deferred basis at payout.

For you as a saver, this time lag means a high degree of legal and planning certainty. If you start with the Altersvorsorgedepot as early as 2027, you benefit from the state allowances and the tax-free accumulation phase from day one. The Article 3 provisions that take effect from 2028 complete the tax framework for the later withdrawal phase, without negatively affecting your ongoing savings phase in the first year.

Article 4 of the AVRG: the role of the Finanzverwaltungsgesetz and data transmission

While the Altersvorsorgedepot already launches for savers on 1 January 2027, key infrastructural provisions such as Article 4 of the pension reform law only take effect on 1 January 2028. Targeted changes to the Finanzverwaltungsgesetz (Fiscal Administration Act) restructure the electronic flow of information between tax offices, product providers and the Zentrale Zulagenstelle für Altersvermögen (ZfA, the central pension allowance office). This delay is meant to give the authorities and IT providers involved the lead time they need to build fully automated interfaces without technical friction.

Fully automated data exchange and less red tape

The core aim of the new rule in the Finanzverwaltungsgesetz is to reduce the administrative burden on savers to a minimum. Instead of manual proof, providers will in future transmit the relevant contribution data directly to the ZfA and the tax administration. If you have submitted a standing allowance application, the check of your eligibility for state support runs fully automatically in the background.

• Direct ZfA interfaces: automatic transmission of all own contributions and allowance entitlements, with no annual paper forms.
• Electronic data transfer: seamless matching between providers and the tax office so contributions are accounted for in the Sonderausgabenabzug.
• Error-free matching: uniform data standards prevent delays in paying out state bonuses.

For the 2027 accumulation year, this staggered commencement places no restriction on your entitlement to state support. The state allowances and tax benefits are yours from day one. The full technical consolidation of the reporting procedures ultimately takes effect once Article 4 comes into force on 1 January 2028.

Article 7 of the AVRG: new transparency and disclosure duties for account providers

While the Altersvorsorgedepot launches on 1 January 2027, key transparency rules of the pension reform law (AVRG) only take effect a year later. Article 7 of the AVRG amends the Altersvorsorgeverträge-Zertifizierungsgesetz (AltZertG, the certification law for Altersvorsorge contracts) specifically as of 1 January 2028. This obliges account providers to meet uniform, detailed disclosure duties, intended to give investors a high degree of comparability. For savers who open an Altersvorsorgedepot as early as 2027, this means: the product launches as planned, but the standards for reporting and cost disclosure are raised to a higher statutory level in 2028.

The key points of the expanded reporting duties from 2028

• Detailed disclosure of effective costs: providers must combine all administrative costs, order fees and product costs (e.g. the TER of ETFs) into a standardised figure. This creates full clarity on all account fees incurred.
• Expanded annual statements: from 2028, contract holders receive a clear annual statement that, alongside the current account value, includes a precise breakdown of the state allowances received and the fees deducted.
• Greater product comparability: uniform figures in the Produktinformationsblatt (PIB, product information sheet) under § 7 AltZertG make it possible to compare accounts from different neobrokers and financial institutions at a glance.

In our view as a neutral guide, this staggered timeline is no obstacle to starting early. Anyone who starts in 2027 benefits from the state allowances and tax-free capital growth in the accumulation phase from day one. The transparency rules that take effect from 2028 then strengthen your options for oversight as an investor. We recommend that, when choosing a provider in 2027, you already check whether an institution voluntarily meets the future AltZertG standards ahead of time.

Article 10 of the AVRG: technical changes to the Altersvorsorge-Durchführungsverordnung

While the Altersvorsorgedepot officially launches for savers on 1 January 2027, important procedural rules only take effect a year later. Article 10 of the pension reform law (AVRG) governs further changes to the Altersvorsorge-Durchführungsverordnung (AltersvorsDV, the implementing regulation for retirement provision), effective from 1 January 2028^[4]. These rules focus on optimising the procedures for data exchange between product providers, the tax administration and the Zentrale Zulagenstelle für Altersvermögen (ZfA). The statutory goal is a transparent, largely automated processing of all tax certificates and allowance procedures.

For citizens who take out an Altersvorsorgedepot as early as 2027, the requirements of Article 10 AVRG mainly translate into reduced red tape. In the reform's first year, providers focus on rolling out the technical interfaces and correctly recording contribution payments. From 2028, the revised electronic reporting procedure under § 92 EStG finally takes effect, reducing ongoing administrative effort for investors to a minimum.

Key areas of the technical transition from 2028

• Standardised electronic reporting procedure: from 2028, contract and contribution data is transmitted to the ZfA via digital interfaces and data formats standardised nationwide.
• Automated certificates under § 92 EStG: the annual statement of allowances and tax-deductible contributions is generated automatically; no handwritten signature or provider name is required.
• Efficient processing of allowance applications: from the second contract year, allowance applications are processed directly in the electronic procedure under a standing allowance application already submitted. Anyone who files it once does not need to submit it again each year.

The time split between the product's 2027 launch and Article 10 taking effect on 1 January 2028 eases the burden on both providers and the tax administration. Savers can therefore build capital from 2027 without procedural hurdles, while the automated allowance matching for the first savings year quietly starts running in the background from the following year.

Impact on savers: what the transition from 2027 to 2028 means for contracts

With the reform law's staggered commencement, savers face one central question: should you wait to sign a contract until 2028, or start straight away in 2027? Based on the key facts, the answer is clear: there is no need to wait. Anyone who opens an Altersvorsorgedepot at market launch on 1 January 2027 secures state support and an early start to building capital on the market from day one. The law articles that only follow on 1 January 2028 primarily concern technical reporting procedures and administrative correction mechanisms between providers and the tax administration, not your entitlement to state support.

Three key points for contracts in the transitional period

• Full entitlement to state support from day one: all own contributions made in the 2027 calendar year are fully eligible for support. Signing a contract in 2027 creates no financial or legal disadvantage for you whatsoever.
• Automatic retrospective capture of reporting data: the data-transmission and subsequent-assessment provisions that take effect from 2028 are handled in the background by account providers and the central allowance office. Where a standing allowance application is in place, the capture happens automatically.
• Continuity in building your savings plan: your account continues into 2028 without interruption, without needing adjustment, and without a change of tariff. The ETF savings plan you chose builds capital from the first month without losing time.

The staggered commencement thus forms an organisational bridge for providers and administration to safely establish interfaces. For your private retirement planning, starting early in 2027 offers the clear advantage that you don't give up a year of state support and can use market opportunities from day one.

Existing contracts and the payout phase: which special rules continue to apply until the end of 2027

The law reforming tax-subsidised private retirement provision has a staggered structure: while the new Altersvorsorgedepot launches on 1 January 2027, downstream articles only take effect on 1 January 2028. For holders of existing Riester-Rente contracts, this transitional period guarantees full protection of existing entitlements. Contracts that continue to be paid into, or are made contribution-free, remain within the previous tax and support framework without automatic conversion^[5].

Special care applies to savers whose payout phase begins before 1 January 2028. Under the statutory transitional provisions in § 52 Abs. 30a EStG, reduction and dissolution amounts from contracts with a pension start before 2028 are calculated under the previous rules of § 22 Nr. 5 EStG, as in force on 31 December 2027. This ensures that the legislature protects ongoing or imminent pension phases from being caught out by the changed reporting duties of the next stage.

• Protection for existing customers: the statutory protection of existing entitlements permanently preserves the guarantees and tax treatment promised under existing contracts.
• Special rules for the start of pension payments: if the payout phase begins before 2028, taxation and record-keeping continue to follow the legal position established up to the end of 2027.
• Targeted transition paths: transferring capital into a new Altersvorsorgedepot is possible voluntarily from 2027, but does not need to be rushed.

We recommend that existing savers weigh up any contract changes objectively against this background. The transitional phase until the end of 2027 offers enough time to assess existing contracts neutrally against the new support structure.

Recommended action for 2027: how to make the most of the staggered start

Although individual provisions of the pension reform law only take effect on 1 January 2028, savers should not wait to act until then — the Altersvorsorgedepot launches on the market on 1 January 2027. The state basic allowance and child allowance, as well as the tax exemption on investment returns, are available from the launch date. Anyone who takes a structured approach from the outset makes the most of the transitional phase and secures full state support from the 2027 contribution year. We recommend a three-step preparation to head off uncertainty early.

1. Check your eligibility for state support: work out your personal eligibility and the minimum own contribution required. The self-employed and career starters should also calculate their individual allowance entitlements in advance.
2. Compare provider terms: when choosing an account, pay close attention to effective costs, execution costs for ETF savings plans, and product ranges. Transparently disclosed account fees vary considerably between providers.
3. Decide on your implementation route: make an objective decision on whether to implement your investment decisions yourself digitally, or seek individual expert advice.

The staggered transition means that automated reporting procedures between providers and the tax administration are fine-tuned by 2028. For you as an investor, this makes no difference to your entitlement to state support in the end. What matters is choosing the right strategy: financially confident self-decision-makers can start directly through neobrokers or direct banks after a provider comparison. If you're unsure about transferring an existing contract or how to split your contributions, the independent advice service offers structured support. Our subsidy calculator helps you work out support rates and own contributions in advance, based on official sources.

Starting early in 2027 means your capital is working in the market from day one and makes full use of the compound-interest effect. The statutory refinements through 2028 primarily concern the administrative processes of the bodies involved and do not affect your return prospects in the accumulation phase.