Crypto at comdirect: 29 certificates with no order fee in a savings plan, but not a single coin

At comdirect you have been able to bet on Bitcoin and Ethereum for years without owning a wallet. What you do not get is a real coin: the bank puts crypto certificates into your securities account, that is, debt instruments tracking the price. How much this route costs you hangs on a single figure from the price list, the minimum fee of 9.90 euros per order. Anyone investing 100 euros in one go therefore pays 9.90 percent in fees. Anyone investing the same amount through a savings plan currently pays nothing.

We evaluated the product page and the schedule of prices and services on October 4, 2026 and recalculated the costs for order sizes from 50 to 25,000 euros. The result separates two groups of investors very clearly from one another.

Crypto trading at comdirect means a certificate, not a coin

comdirect is a brand of Commerzbank AG. On the product page there is the sentence that explains the whole construction: you are not buying a “‘real' coin (cryptocurrency), but a derivative on that cryptocurrency”. The security tracks the price almost one to one, in both directions.

A crypto certificate, often also called an ETP for exchange traded product, is an exchange-listed bearer debt instrument: a loan to the issuer whose repayment is tied to the price of an underlying. That is the decisive difference from an investment fund. comdirect writes it itself: with ETPs and certificates there is “no protection against the insolvency risk of the issuer”. An ETF, by contrast, is ring-fenced assets and stays untouched if the fund company fails.

In practice that means: the units sit in your comdirect securities account like shares or fund units. You do not need a wallet, and you do not get a private key either. Anyone wanting to hold Bitcoin in their own custody is in the wrong place here. Anyone who instead wants everything bundled in one securities account and deliberately forgoes key management gets exactly that.

29 crypto certificates from five issuers: our count

comdirect's savings plan promotion lists the participating securities individually by issuer. We counted them. This analysis was carried out by cryptoticker.io itself on October 4, 2026; the basis is the product page on crypto trading, and 29 securities identification numbers were checked.

The distribution by issuer: 21Shares supplies 15 securities, Bitwise 5, VanEck 5, nxtAssets 3 and Invesco 1. Of the 29 certificates, 22 relate to a single cryptocurrency, the remaining 7 to baskets and indices such as the Krypto Basket 10 or the Krypto Mid-Cap Index.

Twelve cryptocurrencies are covered individually. Five securities run on Bitcoin, 4 on Ethereum, 2 each on XRP, Cardano and Solana, plus one each on Bitcoin Cash, Polkadot, Stellar, Polygon, Litecoin, TRON and Avalanche. What is missing from the list stands out: no security on Dogecoin, none on Monero, none on the big perpetual or staking tokens of the past two years. Anyone wanting to spread more widely has to move to an exchange with a MiCA licence or to a broker with a larger product universe; which providers carry what is shown by our comparison of crypto brokers.

A note beneath the 21Shares tables deserves a sentence of its own: the issuer is domiciled in Switzerland, “so that in the event of the issuer's insolvency Swiss insolvency law applies”. That concerns more than half of the promotion's securities.

Order fee on a one-off purchase: 4.90 euros plus 0.25 percent

For purchases outside a savings plan the normal schedule of prices and services applies. For execution in Germany it sets a basic fee plus order commission of 4.90 euros plus 0.25 percent of the order volume, a minimum of 9.90 euros up to an order volume of 2,000 euros and a maximum of 59.90 euros. On top of that there can be venue-dependent charges and third-party costs. An order by telephone costs an extra 14.90 euros, by fax or letter likewise 14.90 euros. The heavy-trader discount of 15 percent expressly does not apply to savings plan executions.

New securities account customers get a reduction: 3.90 euros order fee per trade on German trading venues and in over-the-counter trading, limited to 12 months. A new customer is anyone who has not held a securities account at comdirect in the past six months. Once those twelve months are up, you trade from 9.90 euros per trade again.

Minimum fee of 9.90 euros: the cost ratio from 50 to 25,000 euros

With small amounts the minimum fee is the entire price. We ran the formula from the price list through typical order sizes, without spreads and product costs, so as a pure fee ratio on the order volume.

Two thresholds shape the table. Up to an order volume of 2,000 euros you always pay 9.90 euros, because the formula of 4.90 euros plus 0.25 percent still sits below the minimum amount there; at exactly 2,000 euros the two values meet. At the upper end the cap of 59.90 euros kicks in, from an order volume of 22,000 euros. Anyone investing larger sums in one go therefore pays more in absolute terms but steadily less in percentage terms.

A plain relationship follows from this: small one-off purchases of crypto certificates are expensive at comdirect. An entry with 100 euros costs almost a tenth of the amount invested before the price has moved at all. At an exchange with a MiCA licence, trading fees for the same amount are typically in the range of tenths of a percent plus spread; which providers are licensed in Germany and what they charge is in our overview of crypto exchanges.

Savings plan promotion until December 31, 2027: the 1.5 percent is waived

Here the calculation flips into the opposite. For the 29 securities on the promotion list, the order fee of 1.5 percent of the order volume per transaction and securities identification number is waived in a savings plan until December 31, 2027. You can invest from 1 euro a month, and up to ten securities can be set up in one pass. Market-standard spreads, inducements and product costs are unaffected by this, as are telephone, fax and letter surcharges.

What that means in figures is shown by a year at 50 euros a month. Normally 1.5 percent would be due on the annual total of 600 euros, that is 9.00 euros in order fees, spread across twelve executions. Under the promotion it is 0.00 euros. The same amount as a one-off purchase costs 9.90 euros. In this product segment the savings plan is therefore not only the more convenient option but, until the end of 2027, by far the cheaper one as well.

Two restrictions belong with it. First, the promotion is time-limited, and comdirect expressly reserves the right to change, extend or end the offer at any time. Second, it does not apply to every type of securities account: accounts of customers who are looked after by a financial services provider, as well as Pure accounts, are excluded. If a certificate drops out of the promotion, the regular terms apply to that security again.

Issuer risk with an ETP: a debt instrument without insolvency protection

The product construction is the point at which crypto certificates differ from everything else in a securities account that otherwise looks like a fund. As a bearer debt instrument, the security carries the risk that the issuer becomes insolvent. comdirect names this issuer risk in its own list of risks and refers to the respective issuer for details of the collateral.

The usual collateral runs through physical backing. According to the account on the product page, the issuers buy the underlying cryptocurrencies in the corresponding quantities and deposit them with independent trustees licensed as custodians for cold wallets. A cold wallet means a storage medium that is not connected to a computer at all, or only briefly. Whether and how far an individual security is backed in this way is disclosed by the issuer in the product details; that belongs to the information you should read up on in the prospectus before buying, not in the marketing copy.

How this product family relates to genuine funds and to the exchange-traded crypto products in Germany is set out in our overview of crypto ETFs in Germany. The short version: what is sold in Germany as a crypto ETF is in most cases legally an ETP or ETN, and therefore exactly the construction comdirect offers.

Spread and product costs: the items beside the order fee

The order fee is the visible part of the costs, but not the only one. In every statement of terms on crypto trading, comdirect names three further items: market-standard spreads, inducements and product costs. The spread is the difference between the bid and the ask price and arises on purchase as well as on sale. The product costs are the issuer's ongoing management fee, which is taken from the security daily and which, with crypto ETPs on the market, is usually well above that of equity ETFs.

For an honest calculation that means: the fee ratio in the table above is a lower bound. The figure names only what the bank takes for execution and says nothing about the ongoing costs of the security. The two values sit in different documents, one in the bank's schedule of prices and services, the other in the issuer's key information document. Anyone looking only at the order fee is comparing half the bill.

Holding period and tax: an ETP in a securities account versus the coin on an exchange

For tax purposes a certificate and a coin are two different things, and the classification depends on the concrete design of the security. comdirect makes no statements on tax on the product page, and we are not asserting any here that cannot be substantiated. What you should clarify before buying is therefore a question for the issuer and for your own tax adviser: is the security treated as an investment product or as a disposal of the underlying cryptocurrency? That determines whether a holding period plays any role at all.

That this question is currently in motion is shown by the Federal Ministry of Finance's draft bill on crypto taxation, which we reported on on October 2, 2026 and which is due to go before the cabinet on October 14. As long as nothing has been decided there, the state of affairs remains today's. For the cost question in this article that changes nothing; for the after-tax return it can change a great deal.

Cost comparison with neo-brokers and licensed exchanges

comdirect plays a clear role in this product class. The bank is strong if you hold a securities account there anyway, think in securities and want to put small amounts into a certificate each month: until the end of 2027 execution in a savings plan costs you nothing. The offer fits less well if you want to buy irregularly and in small sums on a one-off basis, because the minimum fee of 9.90 euros then eats up any return before it arises.

Anyone wanting real coins with their own key will find no offer at comdirect and needs an exchange with a MiCA licence. Anyone wanting to use a hardware wallet needs one in any case. And anyone looking above all at the ongoing costs should lay the issuer's key information document next to the bank's price list before deciding on a route.

Crypto at comdirect: How to proceed now

1. Measure your planned order size against the table above. If your one-off amount is below 1,000 euros, execution costs you at least one percent; in that case the savings plan with 0.00 euros in order fees until the end of 2027 is the cheaper route, and you will find suitable alternatives along with their costs in our broker comparison.
2. Check the issuer's key information document for the ongoing product costs and the type of collateral. For the 15 securities from 21Shares, Swiss law applies in the event of insolvency; that is stated on comdirect's product page. How these securities are to be classified legally is explained by our overview of crypto ETFs in Germany.
3. Decide deliberately about custody. A certificate gives you no private key; if you want one, the route runs via a licensed exchange and from there onto your own device, for which our hardware wallet comparison shows the selection.

What to take away from this: the offer is not crypto trading in the narrower sense but a securities transaction on crypto prices. 29 certificates from five issuers cover 12 cryptocurrencies individually; Dogecoin and Monero are missing. The savings plan carries no order fee until December 31, 2027, while a one-off purchase costs at least 9.90 euros and therefore 9.90 percent on an investment of 100 euros. On top of that come the spread and the product costs, which are waived in neither case. The primary source for all the offer details is the page on crypto trading at comdirect; the fees are in the bank's schedule of prices and services as at June 2026.

(As of October 4, 2026. This article is not investment advice. Prices and fee structures change; check the terms with the provider before you buy.)