A New Pillar 3 for Germany: Private Markets Executives Have Nine Months to Position

Germany's Altersvorsorgedepot does not create a new distribution channel — it creates a new access architecture in which Layer 1 providers hold whitelist authority over every Layer 2 product that reaches German pension savers. Private markets executives who treat that whitelist decision as an operational matter rather than a board-level governance question are building unresolved liability into their infrastructure before the first saver arrives.