The key points
- “Independent” only means an advisor is not tied to one bank or insurer. It does not rule out commissions.
- What you want is fee-only advice (Honorarberatung): the client is the only one paying, so there is no incentive to recommend the product that pays the higher commission.
- Three licences prohibit commissions by law: Honorar-Anlageberater (§93 WpHG), Honorar-Finanzanlagenberater (§34h GewO) and Versicherungsberater (§34d GewO).
- You can check any advisor yourself in the Impressum and the public register — about two minutes.
- Check the fee model: An hourly or flat fee is paid once. A percentage of your assets is charged every year and costs several times more over a decade.
Why “independent” is not enough in Germany
“Independent” is defined more narrowly in Germany than you might expect. It means an advisor chooses between several providers — not that they receive no money from the financial industry.
A broker choosing freely among hundreds of products is still paid by whichever provider’s product you sign — and since different products pay different commissions, there is an incentive to recommend the one that pays most, not the one most suitable for your situation.
The same applies to Honorarberater, which translates as fee-only advisor. The term is not protected. Anyone may use it, including advisors who take commissions.
What counts is not how an advisor describes himself, but which licence he holds. That is what you need to check.
The problem with commissions: the consumer advocates’ view
The Verbraucherzentralen, Germany’s publicly funded consumer advice organisations, consider commissions in financial advice a structural problem and are campaigning to have them banned. In their own reviews of real advice cases, 95% of the investment proposals they examined did not match the client’s actual needs.
There is a cost side too. Small investors, the Verbraucherzentralen write, “pay, through hidden costs and open commissions, a multiple of what would actually be necessary given the modest advisory effort involved.”
They also report that many insurance-based pension contracts they review are still in the red twenty years after signing — while a plain ETF savings plan is so cheap that no intermediary has a reason to recommend it.
The licences that actually prohibit commissions
A financial advisor’s licence decides how they are legally allowed to be paid. Three licences forbid commissions outright:
Honorar-Anlageberater (§93 WpHG) — investment advice on funds and securities, supervised by the federal regulator BaFin.
Honorar-Finanzanlagenberater (§34h GewO) — investment advice on funds and closed-end products, supervised by the regional Chamber of Commerce (IHK).
- Versicherungsberater (§34d GewO)— insurance advice, also supervised by the Chamber of Commerce.
They are legally barred from accepting commissions, kickbacks or any payment from a product provider. Your fee is their only income from the engagement.
Three other licences permit commissions, and these cover the large majority of advisors in Germany:
Finanzanlagenvermittler (§34f GewO) — advises on investment funds, paid by the fund provider.
Versicherungsmakler (§34d GewO) — insurance broker, legally required to act in the client’s interest but paid by the insurer.
Versicherungsvermittler (§34d GewO) — insurance intermediary, paid by the insurer.
One combination is worth knowing about: an advisor can hold a licence that prohibits commissions on funds and a second one that allows commissions on insurance.
That creates a conflict of interest of its own, since there is an incentive to place cheap ETFs inside an expensive insurance wrapper in order to earn a commission (more on this below).
Bank employees are a category of their own. If you walk into a local Sparkasse or Volksbank, the person across the table works for that bank and will recommend its products.
That is not independent advice in any sense — it is sales, and it is usually where internationals start, because the bank is the first financial institution they deal with in Germany.
How to check any financial advisor in two minutes
Fortunately, verifying the licence of an advisor is easy. The German authorities publish the information, so you can check for yourself whether someone really works on a fee-only basis or takes commissions.
Open the Impressum. Every German business website must carry a legal notice, usually linked in the footer. Advisors must state their licence there, with registration number and supervisory authority. Honorar-Finanzanlagenberater gemäß §34h GewO is a legal statement, not marketing copy.
Look them up in the register. The Chamber of Commerce runs a public register at vermittlerregister.info covering all licences under the Trade Regulation Act — §34d, §34f and §34h. Search by name or registration number, and the entry shows which permissions the person actually holds.
- For Honorar-Anlageberater (§93 WpHG), check the BaFin register. BaFin (Bundesanstalt für Finanzdienstleistungsaufsicht) is Germany’s federal financial supervisory authority, roughly the equivalent of the FCA in the UK or the SEC in the US.
Watch out for ETFs inside an insurance wrapper
There is one more thing to watch for: an advisor can hold a fee-only licence on investments and a commission-based licence on insurance at the same time.
That opens a side door. ETFs have an excellent reputation in Germany, and advisors now often sell them inside an insurance policy — a fondsgebundene Renten- or Lebensversicherung, usually presented as a way to save tax.
The ETF itself pays no commission to anyone. The wrapper around it does, for as long as you hold it.
So if your advisor also covers insurance, you want them to be a Versicherungsberater — the fee-only licence on the insurance side. And if someone suggests wrapping your investments in a policy, ask what they earn on it.
What the consumer advocates say
The Bund der Versicherten calls fund-linked policies “fundamentally unsuitable” for retirement saving: expensive, inflexible and hard to see through. The association is a non-profit consumer protection organisation with around 45,000 members.
Its core advice: keep insurance and investing separate. Retirement saving is an investment question, not an insurance one.
Looking for independent financial advice?
In a free, no-obligation intro call you can find out how fee-only advice on an hourly basis works, and get a first read on your situation. Around 30 minutes, online.
The fee model matters as much as the licence
Finding a genuinely commission-free advisor is only half the job. Fee-only advisors charge in very different ways, and the difference compounds.
Hourly or flat fees are billed once, for work actually done. Rates for fee-only investment advice in Germany typically run between €150 and €300 including VAT. When the engagement ends, the cost ends.
A percentage of assets under management is charged every year, usually 0.7% to 1.2% for portfolios under €1 million. It looks small as a number and is not small as a bill. It also grows with your portfolio, for work that has not changed.
Example: You invest €200,000
Hourly advisor |
Percentage-based advisor | |
|---|---|---|
How it is charged
|
Time actually spent
|
0.8% of the portfolio, per year
|
Year 1
|
€2,000 (10 hours at €200)
|
€1,600
|
Year 2 onwards
|
€0
|
€1,600 — more or less, as the portfolio moves
|
Over 10 years
|
€2,000
|
€16,000 — higher or lower depending on how the portfolio develops
|
Source: Own calculation.
As the calculation shows, the hourly model is far cheaper over ten years: €2,000 against €16,000. The assumption here is conservative — the portfolio is taken to be worth €200,000 at every annual assessment, so the percentage fee stays flat.
The argument for paying it is that someone manages the portfolio for you. In Germany that is rarely necessary: a broadly diversified ETF portfolio takes a few clicks a year, and your broker withholds the tax automatically, so there is usually nothing to file.
“Managing an ETF portfolio is easy — a few clicks and maybe 30 to 60 minutes a year. Charging 0.8 or 1% of someone’s assets every year for that is simply overcharging the client.”
In short
Two things to check. First, the licence: look for a Honorar-Finanzanlagenberater (§34h GewO), Honorar-Anlageberater (§93 WpHG) or Versicherungsberater — not Finanzanlagenvermittler (§34f), Versicherungsmakler or Versicherungsvermittler (§34d). Second, the fee model: an hourly rate or a flat fee rather than a percentage of your assets. Both are verifiable before you book a single meeting.
Frequently asked questions
How do I find an independent financial advisor in Germany as an expat?
Look for a Honorarberater — literally “fee advisor”, meaning someone paid only by you. “Independent” is not a protected term here and also covers brokers paid by commission.
How do I know if my advisor is getting paid by the financial industry?
Open the Impressum on their website — the legal notice German sites must carry, usually in the footer. The licence has to be stated there. Honorar-Finanzanlagenberater (§34h GewO) and Honorar-Anlageberater (§93 WpHG) are legally barred from keeping commissions; anything else may earn them. You can verify a licence in the public registers kept by the Chambers of Commerce (IHK) and BaFin.
How do I find an English-speaking financial advisor in Germany?
Search Google for “fee-only financial advice Germany”. That brings up the advisors who work in English, and it tends to filter out the commission-based firms. Still check the Impressum afterwards, and only go with someone listed as Honorar-Finanzanlagenberater or Honorar-Anlageberater.
How much does an hourly financial advisor cost in Germany?
Hourly rates typically run from €150 to €300 including VAT. That is comparable to what lawyers and tax advisors charge in Germany. A straightforward engagement is often five to ten hours.
Do I need a special advisor because I’m a foreigner?
Not for the basics — if you live and pay tax here, the same rules and products apply as to German residents. The exception is US citizens and green card holders, who face separate US tax rules and need a cross-border specialist.
What are the red flags when choosing a financial advisor in Germany?
No. Advisors who bill by the hour charge for the time spent, not the size of your portfolio, so there is no minimum that makes it worthwhile.
Do I have to be wealthy to get fee-only advice in Germany?
No licence named in the Impressum. A fee-only investment licence combined with a commission-based insurance licence. Prices given only as percentages.
My advisor suggested an ETF inside an insurance policy. Is that a good idea?
A German consumer organisation advise against it. The Bund der Versicherten considers unit-linked policies unsuitable for retirement saving and recommends keeping insurance and investing separate.
Can my financial advisor do my German tax return?
No, that is reserved for licensed tax advisors (Steuerberater). An investment advisor can explain how investment taxation works, but not file for you.