ING and Bitcoin: Around 50 Crypto ETNs in the Portfolio, and What the Delivery Claim Means for Your Holding Period

You can buy Bitcoin at ING, but not as a coin. What ends up in the bank's Direkt-Depot are crypto ETNs: exchange-traded notes that track the price of a cryptocurrency. The bank lists around 50 of them in a promotional offer, from five issuers, as a one-off purchase or as a savings plan from one euro per instalment. You need no wallet for this and no private key. What you hold at the end is a security, not a cryptocurrency, and two things hang on that distinction that cost or save more money over the years than any order fee: the ongoing product costs and the question of whether the one-year holding period applies to you.

This article sorts out ING's crypto investments: what is tradable, what trading costs, who really pays the zero-euro order fee, and what the tax treatment equal to a direct purchase of Bitcoin actually depends on.

Can you buy Bitcoin at ING? Crypto ETNs yes, coins no

ING lists crypto as a separate product group within its securities offering, not as a crypto exchange. On its product page the bank describes the offer as access to Bitcoin and other cryptocurrencies without a wallet and without private keys, traded through the existing Direkt-Depot. No account at a crypto exchange is needed for this, and no custody solution either: these securities sit in the portfolio like a share or an ETF, with the same settlement and the same tax statement.

What the bank does not offer is the purchase of real coins. There is no crypto trading, no ING wallet and no way to send purchased Bitcoin to your own address. Anyone who wants to hold the coins themselves needs a crypto exchange or a broker with delivery; you will find an overview of the providers with German authorisation in our comparison of regulated crypto exchanges.

For many investors that is precisely the appeal. The portfolio is familiar, the tax statement comes from the bank, and the question of where to keep the key never arises. The price for that is in the product documents, and it is higher than the order fee suggests.

What a crypto ETN is: a bearer note, not a crypto asset

An ETN is an exchange traded note, a listed debt security; in the plural the industry speaks of exchange traded notes. Legally it is a promise by the issuer to pay you the value of an underlying asset, and not a stake in assets that belong to you. The key information document for the VanEck Bitcoin ETN contains this sentence: “The product is a bearer debt security under German law.” It is certified by a global note held in custody at Clearstream Banking Frankfurt.

The difference from an investment fund matters, because it is often lost. An ETF is a separate pool of assets: investors' money is segregated from the assets of the fund company and survives the insolvency of the provider. An ETN has no such segregated pool. It is a claim against a company, and that claim is only as good as the company and the collateral it has posted for it. Physically backed means, for the common crypto ETNs, that the issuer stores the corresponding amount of cryptocurrency with a custodian for every note issued.

How this product type differs from certificates and directly held coins is something we have broken down in a separate article: Bitcoin certificate, ETN or coin compares the three routes for your portfolio. If you want to sort out the product category as a whole, the overview is at buying a crypto ETF in Germany.

Around 50 crypto ETNs from five issuers: what you can trade in the portfolio

On its crypto page the bank names five premium partners as issuers: 21Shares, Bitwise, VanEck, WisdomTree and iShares. The promotional offer covers around 50 crypto ETNs. That spans the large underlying assets, Bitcoin above all, plus Ethereum and Solana, and depending on the issuer further crypto assets and index products that bundle several coins.

Which ETN belongs to which underlying is something you read from the ISIN and the product name, not from the issuer alone: each of the five providers runs several notes. The VanEck Bitcoin ETN carries the ISIN DE000A28M8D0, the issuer is VanEck ETP AG, and the Liechtenstein financial market authority FMA is responsible for that product's key information document. The fact that an ETN is tradable in Germany and carries a German ISIN therefore does not mean that the issuer is under German supervision.

Each of these notes tracks performance through a reference price. For the VanEck product that price is calculated by MarketVector Indexes GmbH, a company affiliated with the issuer, from the prices of the most important trading venues for digital assets, weighted by liquidity. The product's price is determined on every business day. For you that means the quote in your portfolio follows an index calculated by a company within the issuer's group, not the price of a single exchange where you could buy yourself.

The zero-euro order fee is paid by the issuer, not the bank

Under the promotional offer, buying the crypto ETNs carries an order fee from zero euros, plus product costs, spreads and inducements. That footnote is the interesting part. The bank explains the promotion itself: during the promotion a reduced order fee applies, and the bank is reimbursed for it by the distribution partner, meaning the issuers. The term for this is an inducement.

The arithmetic behind it is simple. The issuer earns its money from the ongoing costs of the product, which it deducts from the invested value every year, and not from your individual order. The longer you hold the note, the more it earns. Covering an order fee that is charged once is, for the issuer, an investment in a holding that pays annually. The purchase is therefore free only at the till, not over the holding period.

ING also expressly reserves the right to end promotions at any time, to change their terms or to postpone announced promotions. The zero-euro order is thus a condition subject to withdrawal and not a guaranteed feature of the portfolio. Anyone calculating for the long run does better to calculate with the standard order fees in the price list and to check them in the portfolio before buying. How widely German providers differ on order fees and spreads is shown in our crypto broker comparison.

Running costs of 1.00 percent: what the key information document works out

The key information document for the VanEck Bitcoin ETN puts management fees and other administrative or operating costs at 1.00 percent of the invested value per year, estimated on the basis of the previous year's actual costs. Transaction costs inside the product are stated as 0.00 percent. The issuer charges no entry fee and no exit fee either, although the selling institution may charge fees of its own.

The document works it out using an example of $10,000: exiting after one year, total costs are $100; exiting after five years, $490. The annual cost impact is 1.0 percent in both cases. As a recommended holding period the issuer states five years.

Transferred to a smaller sum: anyone who puts 1,000 euros into a product with 1.00 percent ongoing costs pays around ten euros in the first year, regardless of whether the price rises or falls. On a direct purchase at an exchange this item does not arise; there you pay a trading fee and the spread when you buy and when you sell, and nothing after that, but you carry the responsibility for custody yourself. The calculation therefore comes down to a threshold: the holding period beyond which the ongoing product fee exceeds the one-off trading fee of a direct purchase.

Crypto ETN savings plan from one euro: where it differs from an ETF savings plan

Crypto ETNs can also be bought through a savings plan at ING. The bank states the execution fee in the discounted savings plan as zero euros, plus product costs, spreads and inducements, and names a minimum instalment of one euro. That puts the crypto ETN in the savings plan range alongside ETF, fund, share, ETC and certificate savings plans.

Technically it works like any securities savings plan: on the execution date the bank buys units for the instalment, fractional units included. The difference from an ETF savings plan lies in the product underneath, not in the mechanics. An ETF savings plan buys units in a segregated pool of assets, a crypto ETN savings plan accumulates debt securities of a single issuer. Anyone saving over years is therefore also building concentration risk towards that issuer, and it grows with every instalment.

A second point concerns tax and is often overlooked: in a savings plan every instalment has its own acquisition date. If the one-year holding period applies to your product, it runs separately for each individual instalment. After a year of saving, then, the whole holding is not free, only the instalments that are more than twelve months old.

Tax: why the delivery claim decides the one-year holding period

On its product page ING lists among the opportunities the tax treatment equal to a direct investment in cryptocurrencies, and adds that price gains may be exempt from capital gains tax on a holding period of more than one year. That is the bank's position, and it describes the favourable case accurately. What the sentence does not say is what that equal treatment depends on.

What matters is whether you, as the holder of the note, have a claim to delivery of the cryptocurrency. If such a delivery claim exists, the tax authorities regularly treat the sale like the disposal of the crypto asset itself, that is as a private disposal transaction under Section 23 of the German Income Tax Act, with the one-year deadline and the exemption threshold within that period. If the delivery claim is missing, or the note tracks the price synthetically through derivatives, the instrument is a monetary claim: then the flat-rate withholding tax under Section 20 of the Income Tax Act applies, with no holding period at all, and even a sale after ten years remains taxable.

This is exactly where it pays to look into the product documents instead of the advertising. The key information document for the VanEck Bitcoin ETN states: “Investors may, under certain conditions, demand redemption in kind or, in limited cases, redemption in cash directly from the issuer.” Redemption in kind means delivery of the coins. The same document, however, also states that authorised participants are empowered to acquire baskets of 50,000 notes from the manufacturer and to return them to it. The precise conditions for redemption are governed by the final terms, not by the information document.

Our assessment: equal tax treatment is a question about the individual product and not a property of the category. The evidence for that is in the documents themselves, namely in the combination of redemption in kind “under certain conditions” and a basket size of 50,000 units for authorised participants. Anyone sitting on a three-digit number of notes in their portfolio should therefore check before buying what claim the final terms actually grant them personally, and discuss the result with a tax adviser. Against that stands the fact that for years the tax authorities have in practice treated physically backed products with a delivery claim like a direct investment; a binding ruling on a specific note is not replaced by that. How to document holding periods and acquisition dates cleanly across several portfolios is shown in our comparison of crypto tax tools.

On top of that, a change is on the horizon: a draft bill from the German Federal Ministry of Finance would tax gains from crypto assets as investment income in future, irrespective of the holding period, and a parliamentary paper from May 2026 on the subject is before the Bundestag. Nothing has been decided. For the current year the one-year deadline applies unchanged, and as things stand the drafts would affect only assets acquired after December 31, 2026.

Issuer risk: what the global note at Clearstream means and what it does not

ING names issuer risk expressly in its list of risks: in the event of the issuer's insolvency, the holder of the ETN faces a risk of loss up to and including total loss. That sentence is not a mandatory platitude, it describes the legal core of the product type.

The global note at Clearstream Banking Frankfurt ensures that the security can be held in custody and transferred at all. It is not security for the value of the claim. What counts in an insolvency is the coins on deposit and the legal construction by which they are allocated to the holders of the notes. Physically backed means that the cryptocurrency is genuinely stored; whether and how quickly you can reach it in insolvency proceedings is governed by the terms of issue and by the law at the issuer's domicile.

A second right appears in the same documents: the issuer may call the product before the maturity date, and the redemption amount may then be lower than the amount that would have been expected at the end of the term. The maturity date of the VanEck Bitcoin ETN is December 31, 2039. A call before that date is possible, and it would trigger the sale whether the timing suits you or not. Which documents you should go through before buying is something we have written up in our article on issuer risk in crypto ETNs.

Risk class 6 of 7 and the securities knowledge on file

In the key information document the VanEck Bitcoin ETN is classified in risk class 6 on a scale of 1 to 7. The issuer offers no capital guarantee, there is no guaranteed minimum return, and the investor may lose all or part of their investment. The risk indicator is based on the assumption of a five-year holding period; on an earlier sale the actual risk may differ considerably.

ING therefore sets a hurdle before the first order: to trade these products, securities knowledge must be recorded in the portfolio. The bank points out that crypto ETNs are suitable above all for experienced investors who can assess the opportunities and risks. Anyone who has not kept those details up to date in their portfolio will have the order rejected and must add the knowledge first.

The same list of risks at the bank contains four further points that advertising material tends to leave out: the high risk of loss from the volatility of prices, regulatory uncertainty, because changes in the law can heavily influence prices and taxation, the susceptibility of crypto markets to manipulation and fraud, and liquidity risk, meaning the danger of not being able to trade crypto assets at fair market prices. Total loss is possible in this asset class.

ETN, ETP or ETF: why Germany has no true Bitcoin ETF

The three abbreviations get used interchangeably, in press coverage too. ETP is the umbrella term for exchange-traded products and covers ETFs, ETCs and ETNs. An ETF is an investment fund with a segregated pool of assets. An ETC tracks commodities. An ETN is the debt security at issue here. ING describes crypto ETNs on its page as exchange-traded products that track the performance of cryptocurrencies, and also calls them crypto trackers.

A fund under European law may not put its assets into a single cryptocurrency, because the rules on risk diversification prevent it. In Europe that limit is the reason for the entire ETN construction. That is why Germany has no Bitcoin ETF in the legal sense, even though the term is everywhere. What exists are ETNs and ETCs on crypto assets. The spot products approved in the United States are called ETFs there, but they are subject to different rules and are generally not tradable for a German portfolio.

For your portfolio that yields a clear reading rule: when a provider speaks of a crypto ETF, it is worth looking into the key information document to see which product type is named there as the type. If it says bearer debt security, you are holding an ETN, and issuer risk and the tax question described above apply.

Portfolio versus your own wallet: when the detour through a securities account pays off

ING's offer has a clear addressee: investors who already run a securities portfolio, who see crypto assets as an admixture in their asset statement and who do not want to take on responsibility for a private key. For them the barrier to entry disappears that an exchange account with verification and a withdrawal address represents. The bank names as further advantages a reduced third-party risk, because no dependence on external crypto services arises, and lower spreads compared with a direct investment.

Three things argue against the portfolio route that cannot be negotiated away. The ongoing product costs continue every year, in a sideways market too. Issuer risk is added to price risk rather than replacing it. And the coins do not leave the product: you cannot spend them, cannot transfer them, cannot use them for staking and cannot move them onto a hardware wallet of your own.

Anyone who plans to hold or move crypto assets themselves anyway is paying, with an ETN, for a wrapper they do not need. In that case the direct route runs through an authorised exchange with withdrawal to your own address, with everything that entails in terms of responsibility.

ING and Bitcoin: without a delivery claim the holding period stays open

Around 50 crypto ETNs from five issuers, a zero-euro order fee during the promotion and a savings plan from one euro make getting started at ING convenient. The two items that count over the years sit elsewhere: in ongoing costs of one percent a year and in the question of whether your note grants a delivery claim. Three steps before you send off your first order:

1. Read the product documents before you buy. Take the ISIN of the note that interests you and look in the key information document to see which product type is stated there, how high the ongoing costs are and when the term ends. How to work through these documents is set out in our crypto broker comparison.
2. Settle the delivery claim before you rely on the one-year deadline. Request the final terms of your product from the issuer and have the tax treatment for your case confirmed by a tax adviser. You document the holding periods and acquisition dates with the tools from our comparison of crypto tax tools.
3. Calculate the portfolio route against the direct purchase. Set the ongoing product fee against your planned holding period and compare it with the trading fee and spread at an authorised exchange from our comparison of regulated crypto exchanges. If you want to hold the coins yourself anyway, the decision is made there.

(As of October 10, 2026. This article is not investment advice. Prices and fee structures change; check the terms with the provider before you buy.)