Can My Employer Pay Into the Altersvorsorgedepot?

Katrin Straub

Published on 24 August 2026 · Managing Director, imatch GmbH

This article was written by an author with the support of AI.

The Conditional Answer: No Gross Salary Sacrifice into the Depot

No, classic gross salary sacrifice as found in company pension schemes is legally not possible for the Altersvorsorgedepot. Yes, your employer can still support you financially, but exclusively via voluntary net payments or capital-forming benefits (Vermögenswirksame Leistungen) into an appropriately qualified depot account. A tax- and social security-exempt deduction directly from gross salary does not exist for the new depot model.

Launching in 2027, the Altersvorsorgedepot is anchored as a purely private pension contract in the Pension Reform Act (Altersvorsorgereformgesetz - AVRG). State allowances, such as the basic allowance of up to 540 euros per year starting in 2027, are tied to the individual and flow directly into the employee's depot. If your employer voluntarily contributes additional amounts, this payment is always made from already taxed and social security-deducted net income.

• No gross salary sacrifice: The Altersvorsorgedepot is not an implementation channel for occupational pension schemes (bAV).
• Net contribution possible: Employers may voluntarily transfer amounts to the depot account, but these are subject to regular income tax and social security contributions.
• Entitlement to subsidies remains private: State support up to the maximum contribution amount is granted exclusively to the eligible account holder.

Clear Separation: Why the Two Subsidy Systems Do Not Mix

The strict separation between company pension schemes and private provision is based on clear legal jurisdictions. § 1a of the German Company Pension Act (BetrAVG) governs the legal entitlement to gross salary conversion exclusively for occupational pension schemes (bAV).^[1] This entitlement is bindingly limited to the five recognized implementation channels: direct insurance (Direktversicherung), pension fund (Pensionskasse), pension institution (Pensionsfonds), direct commitment (Direktzusage), and support fund (Unterstützungskasse).

The Pension Reform Act (Altersvorsorgereformgesetz) does not create a new implementation channel within occupational pension schemes. The social security exemption for salary conversion is explicitly tied by § 14 Abs. 1 Satz 2 SGB IV to salary conversion pursuant to § 1 Abs. 2 Nr. 3 BetrAVG in the implementation channels Direktzusage and Unterstützungskasse, while for the insurance-based channels the exemption follows from the Sozialversicherungsentgeltverordnung^[2]; the tax exemption under § 3 Nr. 63 EStG likewise only applies to contributions to company pension institutions such as Pensionsfonds, Pensionskassen, or direct insurance^[3]. These privileges therefore do not apply to a private securities depot. The two subsidy systems remain legally independent of each other.

What your employer can do: Net payments and capital-forming benefits (VL)

Even though gross salary conversion is excluded, employers still have two concrete options to support their employees' private retirement planning: direct net subsidies and capital-forming benefits (Vermögenswirksame Leistungen - VL).

Voluntary net payments and capital-forming benefits

An employer can agree to transfer regular amounts directly to the clearing account of your Altersvorsorgedepot. Since this constitutes standard taxable salary, the amounts must be fully taxed and subject to social security contributions in advance. An offset against the statutory AVD allowance does not occur at the employer level.

Capital-forming benefits (VL) under the Fifth Capital Accumulation Act (5. VermBG) can also be directed into eligible investment forms, but for tax purposes they do not count toward subsidized retirement provision contributions pursuant to § 82 Abs. 4 EStG. This prevents double statutory subsidization. Retirement-oriented capital-forming benefits (AVWL) established in collective bargaining agreements flow primarily into bAV contracts or separately certified investment structures.

The 15 percent subsidy applies only to bAV

The mandatory employer subsidy of 15 percent pursuant to § 1a Abs. 1a BetrAVG exists exclusively within occupational pension schemes.^[1] It is strictly tied to the condition that the employer saves on social security contributions through the salary conversion. Because contributions to an Altersvorsorgedepot do not reduce ancillary wage costs for the employer, there is no statutory obligation for such a subsidy.

Assessing your starting position: Three concrete tests for employees

To determine how best to combine company pension plans with a private depot, you should evaluate your current contractual situation based on three core questions.

1. Does your company have a binding pension scheme policy (Versorgungsordnung)? Check whether your employer already offers a framework agreement with fixed terms or group discounts for the bAV. In this case, the implementation channel for employer-funded components is predefined.
2. Are you already using salary conversion? If you already convert portions of your gross salary through your employer, you may already be utilizing the tax-free allowances under § 3 Nr. 63 EStG in whole or in part. An additional depot then serves as an independent, flexible supplement.
3. Does the employer contribute more than the statutory minimum? If your employer offers voluntary contributions exceeding the mandatory 15 percent statutory subsidy (e.g., 20 to 50 percent employer matching), the bAV is mathematically difficult to beat with an unsubsidized net model.

Reviewing these points clarifies whether occupational pension schemes or a private pension insurance and the Altersvorsorgedepot provide the more suitable foundation.

Outlook from 2027: Established laws and practical implementation

The Pension Reform Act has been passed, and the official launch date for the Altersvorsorgedepot is set for January 1, 2027. While the core parameters—such as allowance amounts, the elimination of guarantee requirements, and subsidy limits—are legally defined, the precise administrative procedures for interfaces between payroll systems and depot providers will continue to take shape gradually until the market launch.

In parallel, occupational pension schemes are undergoing further regulatory development under the Second Company Pension Strengthening Act (Betriebsrentenstärkungsgesetz).^[4] For employees, this means the dividing line between the two pillars remains in place, yet product providers and employer associations will establish standardized processes for employer-facilitated deposit routes by 2027.

The next step: consultation on your pension plan scheme

Which payments your employer can make and how these are treated for tax purposes depends fundamentally on the specific arrangements in place at your company: a pension scheme (Versorgungsordnung), a collective bargaining agreement, or an individual direct insurance policy. A general guide can outline the various structures, but it cannot review your individual company agreement.

Online calculators cannot automatically model company-specific commitments and complex pension schemes. If you want clarity on your personal starting position, personal financial advice offers the most reliable route. The independent advisor matching service from Vorsorgedepot-Lotse connects you with licensed experts who review your existing contracts and transparently explain where the statutory framework ends and which combination of bAV and Altersvorsorgedepot makes the most sense for your situation.

(Note: The model calculations and comparisons shown serve informational purposes only and do not constitute investment advice pursuant to § 1 Abs. 1a Nr. 1a of the German Banking Act [KWG].)

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