From 1 January 2027, the effective costs of a standard depot contract for retirement provision may not exceed 1.0 per cent. Before first distribution, the effective costs stated in the sample product information must also be confirmed by a certified public accountant (Wirtschaftsprüfer), sworn auditor (vereidigter Buchprüfer) or DAV actuary.
Anyone developing a corresponding product for 2027 should therefore keep the new requirements in view from an early stage and prepare in a structured manner.
Effective Costs in the Standard Depot – Key Points at a Glance
- For standard depot contracts, an effective cost cap of 1.0 per cent applies from 1 January 2027.
- Effective costs are based on the Total Expense Indicator (TEI) in Annex VI of Delegated Regulation (EU) 2017/653.
- Before first distribution, sample product information must be prepared for each tariff variant and the required confirmation obtained.
- Confirmation must be obtained at least every three years from a certified public accountant (Wirtschaftsprüfer), sworn auditor (vereidigter Buchprüfer) or DAV actuary.
- The confirmation covers the mathematical accuracy of the stated effective costs and, for the standard depot, additionally compliance with the 1.0 per cent cap.
- The obligation to determine and confirm effective costs applies more broadly: to guarantee products, Wohn-Riester contracts and the general retirement depot, as well as to the standard depot.
What does the new § 2a AltZertG regulate?
The Act on the Reform of Tax-Favoured Private Retirement Provision (Altersvorsorgereformgesetz) was promulgated on 26 May 2026 in the Federal Law Gazette BGBl. I 2026 No. 156 and is to be implemented from 1 January 2027.
A retirement provision depot (Altersvorsorgedepot) is being newly introduced. The standard depot is a sub-form of this and sits alongside the known guarantee products.
The obligation to determine and have effective costs confirmed applies not only to the standard depot, but also to classic guarantee products, certain Wohn-Riester contracts and the general retirement provision depot.
For the standard depot, § 2a(2) limits effective costs to a maximum of 1.0 per cent. The determination of effective costs follows the Total Expense Indicator in Annex VI of the PRIIPs Delegated Regulation (EU) 2017/653. The decisive factor is the effective costs stated in the individual product information sheet.
Before first distribution, the provider must prepare sample product information and obtain confirmation from a certified public accountant (Wirtschaftsprüfer), sworn auditor (vereidigter Buchprüfer) or DAV actuary: both as to the mathematical accuracy of the stated effective costs and, for the standard depot, as to compliance with the 1.0 per cent cap.
How Are Effective Costs Determined?
Pursuant to § 2a(1) AltZertG, determination follows the calculation of the Total Expense Indicator in Annex VI of Delegated Regulation (EU) 2017/653. In practice, this means that not only a percentage figure must be calculated. Equally important are the complete mapping of costs, the data used, the underlying assumptions and the reproducible derivation of the result.
An auditable model should therefore make clear which cost components have been taken into account, from which systems the data originate, how parameters are released and versioned, and which controls safeguard the calculation.
Who Confirms the Effective Costs?
The provider must obtain confirmation at least every three years from a certified public accountant (Wirtschaftsprüfer), sworn auditor (vereidigter Buchprüfer) or DAV actuary. It must be confirmed that the effective costs stated in the sample product information have been calculated correctly. For the standard depot, it must additionally be confirmed that the statutory upper limit of 1.0 per cent is complied with.
If confirmation cannot be given, the appointed certified public accountant, sworn auditor or DAV actuary must inform the certification body without delay. Documentation that makes deviations visible at an early stage is therefore worthwhile.
Important: This confirmation obligation applies not only to the standard depot, but to the entire product family of retirement provision contracts. Only the fixed 1.0 per cent cap is restricted to the standard depot.
When Must Confirmation of Effective Costs Be Available?
Before first distribution, the provider must, pursuant to § 7(4) AltZertG, prepare sample product information in an accessible format for each tariff variant and obtain the confirmation under § 2a(3). Sample product information and confirmations must be transmitted electronically to the certification body.
Important: Confirmation is not a subsequent documentation step. It belongs on the critical path to the start of distribution.
Why Does Auditability Begin Already at Product Development?
Whether effective costs can later be confirmed efficiently depends not only on the mathematical formula. Data flows, responsibilities, model changes, control evidence and consistent documentation are equally decisive. If these elements are only brought together shortly before the start of distribution, missing data or non-reproducible calculation steps can lead to time-critical rework.
Early classification of the calculation model, data and evidence does not replace the later independent confirmation, but can make it more efficient.
Calculation of Effective Costs – What Remains Open?
The basic methodology for determining effective costs is established: it is based on the Total Expense Indicator in Annex VI of Delegated Regulation (EU) 2017/653. Further details may be specified by an ordinance of the Federal Ministry of Finance and by calculation procedures of the product information body. Until the product information body is re-established, industry-proven, established and parameterised procedures are to be applied.
Recommendation: Providers should monitor further specification, but should not wait to begin preparation.
What This Means in Practice
Anyone wishing to launch with a standard depot on 1 January 2027 should already take future auditability into account during product development and involve an auditor at an early stage. Waiting for further detailed requirements can lead to time-critical rework before the start of distribution.
Early classification of the calculation model, data and evidence does not replace the later independent confirmation, but can make it more efficient.
Are you certifying a retirement provision contract for 2027 – whether standard depot, guarantee product or general retirement provision depot?
In a brief specialist discussion, we will jointly assess which components of the calculation and documentation can already be prepared and which points need to be monitored as regulation develops.
Your ACCONSIS contact
Bastian Regenhardt
Master of Science
Certified public accountant
Authorised signatory of ACCONSIS
Service phone
+49 89 547143
Email
b.regenhardt@acconsis.de
FAQ on Effective Costs in the Standard Depot and § 2a AltZertG
What are effective costs?
Effective costs show the extent to which costs up to the start of the payout phase reduce the return on a retirement provision contract. Determination is based on the Total Expense Indicator in Annex VI of Delegated Regulation (EU) 2017/653.
Does the 1.0 per cent cap apply to all retirement provision products?
No. The fixed upper limit under § 2a(2) AltZertG applies specifically to the standard depot under § 1(1c). The obligation to determine and confirm effective costs correctly under § 2a(1) AltZertG, by contrast, is broader: it also covers classic guarantee products, certain Wohn-Riester contracts and the general retirement provision depot.
Who may confirm the effective costs?
Confirmation may be given by a certified public accountant (Wirtschaftsprüfer), sworn auditor (vereidigter Buchprüfer) or DAV actuary. For the standard depot, it covers both correct calculation and compliance with the 1.0 per cent cap.
When and how often is confirmation required?
Before first distribution, confirmation must be obtained for the sample product information of each tariff variant. Subsequently, § 2a(3) AltZertG requires confirmation at least every three years.
Which providers are affected?
Depending on licensing, contract design and the specific provider role, this can affect not only insurance companies but also banks, securities institutions or other suitable product providers.
Do providers need to wait with preparation?
No. Further methodological specifications should be monitored. However, data sources, controls and calculation logic can already be structured now.
