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

X-Series | Governance as Alpha

Capital for Resilience Advisors | April 2026

The Altersvorsorge-Reformgesetz passed the Bundestag on 27 March 2026. Ratification is expected May 2026. The AV-Depot goes live 1 January 2027. From that date, no new Riester contracts can be signed. Annual Riester subsidy flows in 2021 exceeded €3.8 billion. That capital now redirects into a structurally new product — one that is simultaneously an asset management vehicle and a banking product.

The window for private markets executives is nine months. It is not a marketing window. It is a structural positioning decision with direct consequences for strategy, P&L, and long-term platform access.

The AV-Depot establishes a two-layer architecture. Layer 1 is the depository — banks, Sparkassen, licensed financial services firms, German AIFMs. Layer 2 is the product layer — ELTIF managers and asset managers supplying eligible products. Layer 2 accesses German pension savers exclusively through Layer 1. The whitelist decision belongs entirely to the Layer 1 provider. Every depot provider offering third-party products alongside its own is simultaneously gatekeeper and competitor.

Three structural decisions cannot be deferred: market access strategy (distribution partnership or acquired infrastructure), cost architecture redesign for AV-Depot eligibility including the Effektivkosten framework and SRI profile alignment, and the unresolved treatment of performance fees under the cost cap — a P&L question that delegated legislation has not yet answered.

The full two-page analysis maps the two-layer architecture, the conflict structure embedded in the whitelist governance, the open questions in delegated legislation, and three questions every private markets executive should be directing to their product, legal, and strategy teams before the legislative window closes.

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