Transferring ETFs into the Altersvorsorgedepot: is an in-kind transfer possible?

Tilman Freyenhagen

Published on 24 July 2026 · Updated on 7 August 2026 · Managing Director & Partner, Alsterspree Verlag GmbH

Why a direct in-kind transfer of ETFs isn't possible

A direct, tax-privileged in-kind transfer of ETF units already held privately into the new Altersvorsorgedepot is ruled out by law^[1]. The enacted reform legislation provides for state allowances and tax benefits solely for fresh cash contributions. So if you already hold a private securities account, you can't simply move the holdings sitting there into the subsidised wrapper via an account transfer.

Cash flow, not assets in kind: the personal-contribution principle

The statutory design requires every eligible contribution to arrive at the retirement account as a cash payment. Only this way can the state body monitor the annual contribution ceilings precisely and calculate the allowances. For experienced investors, this raises the question of whether the detour via a sale in the private account is worth it, in order to reinvest the capital afterwards. When weighing this up, you need to compare the pros and cons in Altersvorsorgedepot or an ETF savings plan. You also need to work out the optimal personal contribution to make the most of the subsidy, without triggering unexpected tax disadvantages by disposing of your existing holdings.

• Sale in the private account: you sell your existing ETF units manually through your current broker, and any gains above your saver's allowance are subject to the regular German capital gains tax (Abgeltungsteuer).
• Transfer of the proceeds: you transfer the freed-up cash balance as a personal contribution to the settlement account of your newly opened Altersvorsorgedepot.
• Reinvestment in the subsidised account: you buy the ETFs you want within the new subsidised structure, where future returns and dividends can grow tax-free.

Please note that such a manual account restructuring can have significant tax consequences. Selling in your private account realises gains, which triggers an immediate tax bill and so reduces the capital available for the compound-interest effect. You should work through these financial-mathematics interactions carefully in advance to check whether the state subsidy offsets this tax disadvantage. Note: not investment advice within the meaning of § 1 Abs. 1a Nr. 1a KWG.

The legal requirement: personal contributions as the basis for the subsidy

Anyone who already runs a private account and is considering simply moving existing ETF units into the new Altersvorsorgedepot via an account transfer (an in-kind transfer) runs into tight statutory limits. Under the law reforming private retirement provision promulgated in May 2026, such a direct in-kind transfer is ruled out by law^[2]. The state subsidy, consisting of allowances and the special-expenses deduction, is tied strictly to monetary personal contributions. This makes clear the strict separation between the new account and a conventional, unsubsidised securities account. Only the inflow of new, liquid capital counts as an eligible contribution.

Clear separation of existing assets and new investment

With this rule, the legislator is pursuing a clear regulatory goal: additional retirement assets should be built up, not existing assets simply restructured to reduce tax. For you as a self-directed saver managing your own finances, this means you first have to liquidate existing ETF positions in your private account, in order to then pay the sale proceeds in as an eligible personal contribution. This detour via a sale, however, has tax consequences: selling the units in your private account triggers the capital gains tax, which can reduce the compound-interest effect. Exactly how this sale plays out mathematically compared with a continuous ETF savings plan after tax has to be calculated precisely case by case.

• Cash contributions only: contributions may only be made as cash payments. Account providers do not accept securities such as ETF units as a direct contribution.
• Subsidy eligibility: only monetary transfers count as eligible personal contributions, which can be claimed with the tax office as part of your income tax return.
• Purpose tie-in: capital paid in this way is locked into the Altersvorsorgedepot for the later payout phase, to secure the tax benefit.

Before you dissolve existing portfolios, you should therefore check exactly how much you actually need to pay in to make the most of the state subsidy. Because an in-kind transfer isn't possible, the switch requires deliberate liquidity planning and a careful tax assessment, so that the tax-fresh start in the Altersvorsorgedepot offsets the transaction costs and tax effects of the sale over the long term.

The cash strategy: liquidate and reinvest

Because a direct in-kind transfer of securities you already hold privately into the new Altersvorsorgedepot is ruled out by law, the only route for switching your assets is the so-called cash strategy. In concrete terms, that means you have to actively sell existing ETF units in your private account, in order to then pay the liquidity this frees up into your subsidised account as fresh money. Under the Federal Ministry of Finance's clear guidelines, only cash contributions are permitted as eligible personal contributions^[1]. For experienced self-directed savers who have already built up a sizeable private portfolio, this forced sale calls for careful tax planning, since realising price gains in the private account triggers the capital gains tax and so directly reduces the liquidity available for the subsidised reinvestment.

The three-step process of transferring capital

To make the restructuring process as smooth and cost-efficient as possible, you should follow a structured, three-step process:

1. Gradual liquidation in the private account: you sell your ETF units in a targeted way through your existing broker. To manage the tax burden from the capital gains tax, it can make sense to spread the sale over several tax years, making use of the annual saver's allowance of 1,000 euros per person.
2. Transferring capital to the reference account: after the sale goes through and the securities are settled, you transfer the proceeds from your existing settlement account to the new reference account linked to your Altersvorsorgedepot.
3. Investing in the subsidised Altersvorsorgedepot: once the money has arrived, you invest the balance under the new subsidised structure. Make sure to time the contributions so you make the most of the maximum state subsidy and the special-expenses deduction in the relevant calendar year.

Before you take this route of liquidation, you should work through the long-term pros and cons carefully. A detailed mathematical comparison between a state-subsidised ETF savings plan and a classic private investment shows you the point from which the tax-privileged compound-interest effect pays off despite the initial tax burden on the sale. Also remember that after opening your account, you need to take all the necessary steps to activate the subsidy and for the right setting up of the savings plan.

The tax trap when selling: minimising capital gains tax

Anyone who already holds a private ETF portfolio and wants to move it into the new, state-subsidised Altersvorsorgedepot runs into a legal hurdle: a direct, tax-free in-kind transfer of ETF units is legally ruled out^[3]. To use the state allowances and tax benefits in the new Altersvorsorgedepot, you have to liquidate your private assets and pay in the proceeds as a cash contribution^[1]. This forced sale immediately triggers capital gains tax if your realised gains exceed the statutory allowances. Without strategic planning, the tax burden can noticeably erode the initial benefits of the state subsidy. In our guide ETF savings plan after tax we set out how this tax burden plays out over the long term.

Experienced investors, then, need to optimise the sale for tax purposes. Make deliberate use of your annual saver's allowance of 1,000 euros for single people or 2,000 euros for jointly assessed spouses, by setting up a corresponding exemption order (Freistellungsauftrag) with your existing broker. If you've already paid the annual advance lump-sum tax (Vorabpauschale) over the years, this is credited against the actual sale and reduces your final tax bill. On top of that, equity ETFs with an equity share of at least 51 percent benefit from a partial exemption of 30 percent, so only 70 percent of the realised price gains are taxable^[1]. To smooth out the tax progression, it can be worth spreading the sale across the turn of the year, to use the allowance from two calendar years.

The worked example shows how a forward-looking spread of sales saves real money and nearly halves the tax bill (Note: the calculations are for illustration only and do not constitute investment advice within the meaning of the KWG). Once the capital is reinvested in the account, it benefits from tax-free reinvestment, since no tax applies during the term. Whether this step pays off for you also depends on how future gains in the Altersvorsorgedepot are treated. Our subsidy calculator helps you weigh up different scenarios mathematically.

Is the restructuring worth it? Subsidy versus tax deduction

Anyone who already holds securities privately and is thinking about switching faces a mathematical trade-off. Because a direct in-kind transfer of ETF units is ruled out by law, existing positions in the private account have to be liquidated^[1]. This sale triggers capital gains tax on realised price gains. Set against that, from 2027 there is the prospect of an annual basic allowance of up to 540 euros, or tax benefits, which we analyse in the comparison after tax.

The mathematical break-even: tax outflow against allowance inflow

The decisive factor for the economics of such a restructuring is the size of the latent tax liability in your current portfolio. If your ETFs have built up substantial gains in value over many years, selling leads to an immediate tax outflow, which reduces the compound-interest capital actively working in your private account. The state subsidy first has to make up for this initial loss over the remaining term. As a rule of thumb for investors: the smaller your past gains and the longer the remaining time until retirement, the sooner the capital gains tax you paid is offset by tax-free reinvestment and the annual allowance in the new Altersvorsorgedepot.

Because every asset situation is individual, no blanket verdict is possible. A high taxable income often shifts the mathematical break-even point clearly in favour of the subsidised account, thanks to the additional special-expenses deduction. To compare the exact tax effects and allowance entitlements for your personal situation, the subsidy calculator is available to you as a neutral tool. In addition, you can familiarise yourself with the new rules in more depth via the knowledge section. Please note: these calculations are for illustration only and do not constitute investment advice within the meaning of paragraph 1, subsection 1a, number 1a KWG.

The cost cap protects the subsidised investment

When you sell private ETF holdings and buy back into the Altersvorsorgedepot, the legislator provides an important safety net. For the statutory standard product, a strict cost ceiling of a maximum of 1.0 percent in effective costs a year applies from the launch in 2027^[4]. This statutory limit effectively protects your restructuring from excessive provider fees. That means: if you liquidate assets from your private account to reinvest them tax-efficiently, this transaction won't be devalued by overpriced product costs. It ensures the compound-interest effect on your subsidised retirement saving can take full effect from the start, without being eroded by unnoticed high distribution or administration costs.

This cost cap means that, as an experienced investor, classic front-end loads on buying the standard product are a thing of the past, and you keep full cost control over your new investment. Even so, bear in mind that this 1.0 percent ceiling merely marks the statutory maximum for standard accounts. To optimise your return further and consistently avoid additional hidden costs, it's worth taking a close look at brokers' actual market terms. Our knowledge section lets you keep up to date with the exact statutory details. A provider comparison also helps you identify low-cost providers or neobrokers that undercut this statutory ceiling even further and offer transparent terms for your long-term investment. Note: these comparisons are for guidance only and do not constitute investment advice within the meaning of § 1 Abs. 1a Nr. 1a KWG.

The optimal contribution plan from 2027

Because a direct in-kind transfer of privately held ETF units into the new Altersvorsorgedepot is ruled out by law, experienced self-directed savers face a strategic challenge. Rather than liquidating a laboriously built-up private account in a single large tranche, and so triggering a hefty tax bill from the capital gains tax, a planned, step-by-step transfer is advisable. By selling smaller partial amounts in a targeted way each year, and then reinvesting them as fresh capital in the Altersvorsorgedepot, you make the most of the state subsidy without needlessly burdening your long-term tax position.

• Form annual tranches: sell only as many units from your private account, systematically, as you need for the annual contribution to the subsidised account.
• Use the maximum personal contribution: transfer exactly 1,800 euros a year to your Altersvorsorgedepot, to capture the full state basic allowance of 540 euros directly.
• Make full use of the tax-free allowance: use your annual saver's allowance cleverly on the partial sales in your private account, to minimise or fully avoid the tax due on realised gains.
• Keep an eye on costs: for the restructuring, choose a very low-cost neobroker from our provider comparison, to keep friction losses from sale and purchase fees as low as possible.

Note: the comparison above is for illustration only and does not constitute investment advice within the meaning of § 1 Abs. 1a Nr. 1a KWG.

To work out precisely whether this restructuring plan pays off for your personal situation, our subsidy calculator offers a well-founded, source-based decision aid. With this tool you compare the tax benefits and allowances of the subsidised Altersvorsorgedepot directly against your existing ETF savings plan after tax. For a comprehensive, tailored analysis of your portfolio, our independent advice service is also available to you, and on request puts you in easy contact with a licensed, neutral expert.

Alternative: leaving the private account untouched instead of restructuring

For experienced investors who have already built up considerable wealth in private ETFs, a very fundamental question often arises: is it actually worth selling existing units entirely, in order to then pay the proceeds in cash into the newly opened, state-subsidised account? Because a direct in-kind transfer of ETF units already held privately is ruled out by the legislator^[1], such a restructuring forces you to take the tax-disadvantaged detour via a sale and the associated realisation of gains. A mathematically highly attractive alternative is therefore simply to leave the existing private account untouched. This way, your entire gross capital, including accumulated gains, stays fully invested and keeps benefiting fully from the valuable compound-interest effect without a tax detour.

Instead of laboriously restructuring assets you've built up over time and thereby prematurely triggering capital gains tax, you can fund the new Altersvorsorgedepot, from its launch in 2027, entirely from your current income. This two-track retirement strategy combines the best of both worlds in a well-balanced way: your private account stays highly flexible and fully liquid for unforeseen life situations, while your new Altersvorsorgedepot benefits from the state allowances and tax subsidy during the important accumulation phase. If you want to compare the financial dynamics of both models in detail for your personal planning, a direct ETF savings plan comparison can help.

Such a two-track strategy can be flexibly adapted to your individual savings instalments and monthly liquidity. With the subsidy calculator (Note: not investment advice within the meaning of § 1 Abs. 1a Nr. 1a KWG) you can easily calculate how much fresh income you should ideally pay in to make efficient use of the maximum state subsidy, without jeopardising your private investment strategy or having to liquidate existing holdings prematurely.