Can I transfer ETFs into an Altersvorsorgedepot?

Tilman Freyenhagen

Published on 25 July 2026 · Managing Director & Partner, Alsterspree Verlag GmbH

The BMF rule in plain terms: why an in-kind ETF transfer isn't possible

Many investors ask the practical question of whether securities they already hold in a private account can be booked directly into the new Altersvorsorgedepot. The legal position here is unambiguous: a direct in-kind transfer of existing ETF holdings into the Altersvorsorgedepot is not legally possible^[1]. Under the statutory framework, the state subsidy is granted only for cash contributions newly paid into the Altersvorsorgevertrag certified under § 5 AltZertG.

1. Sell in the existing account: existing ETF positions have to be sold in the normal way, through your current bank or broker.
2. Tax on the old gains: any price gains are taxed immediately on sale, at the flat-rate capital gains tax (25 percent plus solidarity surcharge and, where applicable, church tax), once they exceed the saver's allowance.
3. Cash payment into the Altersvorsorgedepot: the available net proceeds are paid into the Altersvorsorgedepot in cash, as your own contribution.
4. Crediting toward the subsidy: the amount paid in counts toward the state subsidy within the statutory limits (1,800 euros own contribution plus allowances).

From a regulatory standpoint, this detour requirement keeps subsidised and unsubsidised assets cleanly separated. Because the Altersvorsorgedepot offers full tax exemption on returns during the accumulation phase, the tax authorities require exact traceability of every contribution paid in. Anyone looking to move holdings out of an unsubsidised ETF savings plan therefore has to factor in the tax effect of selling in the existing account. We recommend that investors check their individual acquisition costs and untaxed gains in the old account closely before reallocating. (Not investment advice under § 1 Abs. 1a Nr. 1a KWG.)

Cash payment, not an account transfer: the statutory rules for your own contributions

Under the statutory rules set by the Federal Ministry of Finance (BMF), existing ETF holdings cannot be booked directly into the new Altersvorsorgedepot by an in-kind transfer. The state subsidy is strictly tied to cash payments made as your own contribution into the certified Vorsorgedepot. If you want to use holdings from your unsubsidised securities account for subsidised retirement provision, you have to sell the holdings in the old account and reinvest the cash proceeds as a new contribution. How that's subsidised comes down to one rule: only cash payments qualify for allowances and the special-expense deduction.

Upper limits and the tax consequences of selling

When reallocating securities from an unsubsidised account into the Altersvorsorgedepot, two key conditions apply. First, the annual subsidised maximum for your own contributions is capped at 1,800 euros (plus state allowances). Selling a large ETF portfolio in one go therefore doesn't mean the whole proceeds can be invested with a subsidy at once. Second, selling in the existing account triggers tax on any realised gains. Capital gains tax, plus solidarity surcharge and church tax where applicable, is due immediately on the sale in the old account.

• No in-kind transfer possible: securities cannot be moved directly between an unsubsidised account and the Altersvorsorgedepot.
• Strict ceiling on allowances: only cash is subsidised, up to a ceiling of 1,800 euros per calendar year.
• Tax liability in the old account: gains from selling ETFs are subject to the standard tax on investment income.
• Staged payments: larger account balances have to be paid in over several years to make continuous use of the maximum subsidy.

For investors with existing ETF savings plans, this means strategic planning is needed. Rather than abruptly closing out existing positions, it can make sense to adjust the ongoing savings plan in the unsubsidised account and redirect the monthly subsidised amount straight into the new Altersvorsorgedepot. We recommend checking the tax effect of the sale closely beforehand. Note: this information is for guidance only. Not investment advice under § 1 Abs. 1a Nr. 1a KWG.

Selling ETFs in the old account: the tax consequences of reallocating

Under the statutory rules, a direct in-kind transfer of existing securities from an unsubsidised securities account into the new Altersvorsorgedepot is not possible^[3]. Only cash payments are subsidised, as your own contribution. If you want to bring your existing ETF holdings into the state-subsidised system, that necessarily means selling the holdings in the old account and then paying the cash proceeds back in as a new contribution.

Capital gains tax and the tax deduction on sale

When you sell ETF units in an unsubsidised account, accrued gains become taxable immediately. The sale proceeds are subject to the standard flat-rate capital gains tax of 25 percent, plus a 5.5 percent solidarity surcharge and, where applicable, church tax. After the partial exemption for equity ETFs (30 percent tax-free) and the saver's allowance, the tax due reduces the amount left over to reinvest. This one-off tax deduction reduces the starting capital available for the subsidised new account.

• Realising gains: selling in the old account means capital gains tax is withheld immediately on any accrued price increases.
• Using the partial exemption: for equity ETFs, 30 percent of the realised gain is exempt from tax by law.
• Offsetting your allowance: any remaining saver's allowance (1,000 euros for individuals / 2,000 euros for jointly assessed couples) reduces the taxable gain.
• Watch the contribution limits: the net proceeds can be paid into the Altersvorsorgedepot as your own contribution, up to the annual subsidised maximum of 1,800 euros.

To weigh up whether the tax hit in the old account is worth it against the long-term advantages of the Altersvorsorgedepot, a sound tax comparison helps. While selling in the unsubsidised account costs tax liquidity up front, later gains in the Altersvorsorgedepot benefit from full tax deferral throughout the accumulation phase. (Not investment advice under § 1 Abs. 1a Nr. 1a KWG.)

Allowances and the partial exemption: optimising tax before you sell

Because the statutory rules rule out a direct in-kind transfer of securities from an unsubsidised account into the Altersvorsorgedepot^[5], using existing ETF holdings always requires selling in the old account first. That sale generally triggers capital gains tax on any gains made. To minimise the tax burden before reallocating into the subsidised Altersvorsorgedepot, however, investors can combine existing tax shields deliberately.

The tax levers available when selling in the old account

• Use your saver's allowance in full: capital income stays tax-free up to 1,000 euros per person (2,000 euros for jointly assessed couples) per calendar year. Filing an exemption order in good time avoids capital gains tax on price gains up to that amount directly.
• Use the 30 percent partial exemption for equity ETFs: under the Investment Tax Act, equity funds with an equity ratio of at least 51 percent have exactly 30 percent of their returns exempt from tax. Capital gains tax of 25 percent plus solidarity surcharge therefore only applies to 70 percent of the realised gain.
• Sell in tranches over several years: where cumulative price gains are high, a staggered partial sale spread across several calendar years can make sense, to make optimal use of the saver's allowance more than once.

If you sell shares in an equity ETF with a realised gain, for instance, the 30 percent partial exemption applies first. That proportionally reduces the taxable gain. If you also use your saver's allowance in the same year, in the best case only a small amount, or none at all, is left subject to capital gains tax. The net proceeds can then be paid into the Altersvorsorgedepot as a subsidised contribution. As our analysis shows, the long-term advantages of tax deferral in the subsidised account often outweigh the one-off tax paid on selling in the old account. (Note: not investment advice under § 1 Abs. 1a Nr. 1a KWG.)

Making the most of the subsidy limits: reinvesting into the Altersvorsorgedepot correctly

Because the statutory framework rules out a direct in-kind transfer of securities from an unsubsidised account^[6], switching over requires a well-thought-out reallocation strategy. Anyone wanting to move capital from existing ETF holdings into the subsidised Altersvorsorgedepot has to sell the relevant holdings in the existing account, account for the tax consequences on any gains, and pay the cash proceeds back in as a new contribution. Because the state-subsidised maximum for your own contribution is 1,800 euros per calendar year, a single lump-sum reallocation of a larger account balance is usually neither legally nor financially practical. To secure the maximum subsidy rate per euro paid in, a staggered reinvestment over several years is the most economically sensible route.

• Plan partial sales: each year, sell only as many ETF units from the unsubsidised account as you need to make full use of the subsidised annual maximum in the Altersvorsorgedepot.
• Use your saver's allowance: where possible, offset gains realised on sale against your annual saver's allowance, to minimise the tax burden in the old account.
• Make full use of the 1,800-euro maximum: pay in specifically up to the 1,800-euro-a-year ceiling, to get the full state allowance and the maximum special-expense deduction.
• Leave remaining capital where it is: leave any remaining positions in the unsubsidised account for now, to avoid tax liabilities without immediate state subsidy.

This step-by-step reinvestment gets you the highest subsidy rate per euro deployed. Payments above the annual maximum of 1,800 euros trigger no further state allowances and offer no extra advantage during the accumulation phase over an unsubsidised savings plan, in a tax comparison. Through our Vorsorgedepot-Lotse portal and its built-in Altersvorsorgedepot subsidy calculator, you can work out exactly how the Altersvorsorgedepot is subsidised for tax purposes and what reallocation rate is optimal for your personal situation. (Not investment advice under § 1 Abs. 1a Nr. 1a KWG.)

Tax-free reallocation in the account: the long-term advantages of reinvesting

Even though the statutory requirement to sell ETF units in an unsubsidised account triggers immediate tax on price gains, paying the proceeds back in as a subsidised contribution to the Altersvorsorgedepot brings substantial long-term advantages. Under the rules set by the Federal Ministry of Finance, all capital income stays completely tax-free throughout the accumulation phase. In an unsubsidised securities account, by contrast, dividend payouts and retained gains are subject to capital gains tax as well as the annual advance lump-sum tax. Our neutral tax comparison makes clear how much faster wealth builds up once that tax burden falls away.

• Full tax deferral: during the accumulation phase, neither interest, dividends nor realised price gains are taxed.
• No more advance lump-sum tax: for accumulating ETFs, the annual partial taxation of notional income no longer applies at all.
• Cost-free and tax-neutral reallocation: portfolio adjustments or rebalancing within the account wrapper trigger no taxable event.

Removing ongoing taxation strengthens the compounding effect, because the reinvested gross capital keeps working for you without annual drag. Even where realising old gains in the unsubsidised account triggers a one-off tax payment, the deferral effect of the Altersvorsorgedepot usually offsets that initial cost again over a multi-year remaining term. Deferred taxation only applies later, in the payout phase in retirement, when your personal tax rate is typically lower than during your working life.

When deciding whether to reallocate, you should therefore always weigh up the combination of remaining savings time, gains made so far, and your personal subsidy rate. Note: all model calculations and comparisons are for guidance and information only. Not investment advice under § 1 Abs. 1a Nr. 1a KWG.

Step-by-step guide: from existing ETFs to the subsidised account

Because the rules set by the Federal Ministry of Finance (BMF) rule out a direct in-kind transfer of securities from an unsubsidised account into the subsidised structure, reallocation always runs via selling and reinvesting. If you want to move existing capital from an unsubsidised ETF savings plan into the Altersvorsorgedepot, that requires a structured sequence of selling, accounting for tax, and targeted reinvestment.

Four steps to reallocate existing ETFs

1. Analyse the sale in the old account: before selling your ETF units, check the accrued gains and your available saver's allowance. Realised gains are generally subject to capital gains tax plus solidarity surcharge and, where applicable, church tax.
2. Transfer the money to your reference account: once the sale settles and the net proceeds are credited, transfer the amount you want into the settlement account of your Altersvorsorgedepot.
3. Declare eligible contributions: make sure the amount paid in stays within the annual subsidy limit for own contributions. Keep in mind the annual subsidised maximum of 1,800 euros plus any allowances you're entitled to.
4. Reorganise and set up a savings plan: complete the process by choosing suitable ETFs in the new subsidised account and setting up an automated savings plan or a lump-sum investment.

For a smooth account opening and setup afterwards, it's worth staggering the process over time to reduce market-price risk during the transfer phase. With our Altersvorsorgedepot subsidy calculator, you can simulate in advance how the one-off tax deduction on selling in the old account compares with the long-term tax advantages during the accumulation phase.

Deciding yourself or getting advice: which path suits your retirement plan

Because the regulatory framework set by the Federal Ministry of Finance (BMF) does not allow a direct in-kind transfer of securities from a private account into the subsidised Altersvorsorgedepot, switching over calls for targeted preparation^[8]. To use the state-subsidised Vorsorgedepot, investors have to sell existing ETF holdings in the old account, pay the correct tax on any income realised, and reinvest the remaining cash proceeds as eligible contributions. Two equally valid routes are available for this process, which we compare transparently as a neutral guide.

For decisive investors who want to manage their own strategy, the independent route via modern neobrokers offers maximum flexibility at low product cost. Our provider comparison helps you assess terms neutrally, while the Altersvorsorgedepot subsidy calculator works out the interplay of your own contribution and the state allowance.

If, on the other hand, you're unsure about the tax implications of selling ETFs, or want everything coordinated holistically with your existing retirement provision, being accompanied by qualified advisers is worth it. Through our independent advice service, you get access to vetted financial advisers for a free introductory conversation. Our knowledge section provides all the background for this, including a detailed tax comparison and guidance on app or advice. Please note: all calculations are for illustration only (not investment advice under § 1 Abs. 1a Nr. 1a KWG).