Comdirect and State Street just dropped a new globally diversified ETF that you can supposedly buy without fees. The German investment community’s reaction? A collective eye-roll. While the marketing screams “kostenfrei” (cost-free), the fine print reveals a 0.4% TER that makes this product dead on arrival for most serious passive investors.
The Product: What You’re Actually Getting
Let’s cut through the promotional fluff. The Comdirect S&P All-World State Street UCITS ETF tracks the S&P All World Index, an index many German investors hadn’t even heard of until this launch. The fund covers roughly 4,100 companies across large, mid, and small-cap stocks, with a quality filter applied to the smaller companies. It’s thesaurierend (accumulating) and physisch replizierend (physically replicating), which are standard features for any decent ETF in Germany.
The hook? You can set up a Sparplan (savings plan) on Comdirect’s platform with zero transaction fees. No purchase costs, no order fees, nothing. That sounds revolutionary until you remember that most German brokers already offer free Sparpläne on major ETFs. The real story isn’t what’s free, it’s what isn’t.
The 0.4% TER: Where This ETF Goes to Die
Here’s where the marketing falls apart. The Total Expense Ratio (TER) sits at 0.4% annually, a figure that experienced investors immediately flagged as a “Todesurteil” (death sentence) for the product. For context, the wildly popular Vanguard FTSE All-World UCITS ETF charges 0.22% TER. The iShares Core MSCI World UCITS ETF clocks in at 0.20%. Even Scalable Capital’s recently launched free ETF comes in significantly lower.
That 0.18-0.20 percentage point difference might sound trivial, but over a 20-year investment horizon on a €50,000 portfolio, you’re looking at thousands of euros in extra costs. The math is brutal: Comdirect’s “free” ETF could cost you more than €3,000 extra compared to Vanguard’s offering over two decades. That’s an expensive way to avoid a €15 annual depot fee.
The Hidden Agenda: Depot Fee Hostage Situation
The only scenario where this product makes any sense reveals Comdirect’s true strategy. Many existing Comdirect customers face annual depot fees unless they maintain active trading activity. One investor mentioned their depot “wird im nächsten Jahr kostenpflichtig” (will become fee-charging next year), making this ETF suddenly attractive, not because it’s good, but because it prevents depot charges.
Comdirect essentially created a product that’s less an investment vehicle and more a “depot fee avoidance tool.” You get to keep your account free, but you pay through the nose via TER. It’s a clever retention strategy disguised as innovation. For someone with a small portfolio where the depot fee would exceed the TER premium, this might work. For everyone else, it’s financial masochism.
Whitelabel Fatigue: When “New” Means “Unnecessary”
This launch follows Scalable Capital’s genuinely innovative free ETF and Finanzen.net’s less impressive offering. The community has seen through the pattern, with one investor calling it the “nächste Whitelabel-Lösung” (next white-label solution) in a saturated market. The joke about a “Dirk Müller Premium ETF” with 0.9% TER captures the mood perfectly, German investors are tired of products that serve banks more than customers.
The S&P All World Index choice itself raises eyebrows. While diversification across 4,100 companies sounds impressive, MSCI and FTSE benchmarks dominate the European market for good reason: liquidity, recognition, and, crucially, lower licensing costs. State Street’s index is the new kid on the block, and investors are rightfully skeptical whether those higher costs buy anything beyond marketing differentiation.
Who Could Actually Benefit From This?
Let’s be fair. Three specific groups might find value here:
- Existing Comdirect customers with small portfolios (under €15,000) who’d otherwise pay €15-30 annual depot fees
- Absolute beginners who value the simplicity of a single, set-and-forget solution from a known German bank
- Loyal Comdirect users who refuse to switch brokers regardless of cost
For everyone else, especially anyone building wealth systematically through a Sparplan, this product makes zero financial sense. The 0.4% TER simply cannot be justified when superior alternatives exist at half the cost.
The Bottom Line: Competition Without Value
Comdirect and State Street delivered exactly what the German market didn’t need: another overpriced ETF with a free Sparplan gimmick. Real competition would have meant undercutting Vanguard’s 0.22% TER while maintaining the free savings plan structure. Instead, they launched a product that serves their business model at the direct expense of investor returns.
The controversy isn’t that this ETF exists, it’s that major financial institutions think German investors won’t notice a 0.4% TER in 2026. They noticed. The product forum discussions are already calling it overpriced and unnecessary. If you’re looking for a truly fee-free global ETF strategy, stick with established low-cost providers and switch to a broker that doesn’t charge depot fees. Your future self will thank you when that 0.2% TER difference compounds into a substantial retirement bonus.
The German investment landscape doesn’t need more products. It needs better ones. This isn’t it.
