Comdirect Review
Our take: Comdirect is a broker that combines traditional banking services with a comprehensive investment platform as a subsidiary of Commerzbank AG. It has a reliable German tax reporting, and comprehensive customer service, making it attractive for German investors seeking an integrated financial solution. However, 1.5% fees to purchase ETF Savings Plans make its offer less competitive.
Our assessment: Comdirect’s scores 2.7 in its category. Its integrated approach makes it ideal for investors who want to combine their banking and investment needs under one roof, while the robust tax reporting system particularly benefits German tax residents. However, the transaction fee makes it uncompetitive and heavily impacting our score.
- Passive Investors: The fee structure is higher than its direct competitors and cost-conscious investors might find better value elsewhere for simple buy-and-hold strategies.
- Semi-Active Investors: For semi-active investors, Comdirect delivers a well-rounded package that combines extensive market access with integrated banking services. However, the transaction fee here again makes it a less competitive option.
- Advanced Investors: Advanced investors will find Comdirect’s professional trading platform and diverse product range appealing, including access to derivatives and complex financial instruments, but the fees are partially offsetting the benefits.
Pros & Cons and suitability
Pros & Cons
- Backed by Commerzbank AG which is partly state-owned
- BaFin regulation
- Extensive product range
- Available to German Resident Only
- No Multicurrency
- Transaction fees are expensive
Suitability
somewhat Suitable
Trading fee. Potentially more complex than competitors.
somewhat Suitable
Good choice of exchanges and instruments but very expensive compared to competitors
somewhat Suitable
Advanced options, but high trading fee.
Availability
Comdirect is only Available In Germany
Broker Snapshot
Why Is Comdirect A Bank-backed Fintech Broker?
Comdirect qualifies as a bank-backed Fintech broker due to its fairly advanced platform combined with backing by Commerzbank AG. While it offers comprehensive services and robust protection schemes, it primarily serves the German market with limited international reach. The broker provides good execution quality and although fees are higher than pure-play fintech competitors, its integration with Commerzbank AG provides additional security.
A Subsidiary of Commerzbank, Operating As A fintech
Comdirect is a fully owned subsidiary of Commerzbank after being bought by them in 2020. Since then, Comdirect has joined the Commerzbank group and operated within there, with its services available to Commerzbank customers. It now serves almost 3 million customers. The parent is listed, and rated IG.
Company Info
| Characteristic | Comdirect |
|---|---|
| Inception Date | 🛈 1994 |
| Headquarters | 🛈 Quickborn,, Germany |
| Key Owner | 🛈 Commerzbank AG (100%) |
| Bank Affiliated | ✅ Yes |
| Listed on Stock Exchange | ✅ Yes (Parent) - €18.7 bn |
| Rating (Parent) | ✅ BBB+ (S&P), Baa2 (Moody’s) |
| Net Profit (2023) | ✅ €2.2bn (Parent) |
Regulation
| Feature | Comdirect |
|---|---|
| EU Entity | 🛈 Comdirect Bank AG |
| UK Entity | 🛈 N/A |
| Key Regulators | ✅ BaFin |
| EU Regulator | BaFin |
| UK Regulator | N/A |
| EU Guarantee | €20,000 |
| UK Guarantee | 🛈 N/A |
Good Offering, Low custody fees but high trading Fees
Comdirect has average transaction fees. FX fees are also relatively high and accounts are in Euros only. The offers of ETFs and exchanges is good.
Features
| Feature | Comdirect |
|---|---|
| Key Base Currencies | EUR |
| ETF Availability | ✅ Very High (2,400) |
| Multicurrency | ❌ No |
| Cash Interest | ✅ Yes (variable rates) |
| Margin Loans | ✅ Yes |
| Exchanges | ✅ Major European |
| Security Transfer | ✅ Yes |
| External PFOF Reliance | ✅ No |
Fee Structure
| Feature | Comdirect |
|---|---|
| Custody Fees | ✅ None¹ |
| Inactivity Fees | ✅ None |
| ETFs Dealing Fees | ⚠️ €4.90 + 0.25% ² |
| FX Fees | ⚠️ 0.5% |
| Deposit Fees | ✅ None (SEPA) |
| Withdrawal Fees | ✅ None (SEPA) |
| Security Lending | 🛈 Not Available |
² Normal Trades. ETF Savings Plans charged at 1.5% per transaction
I. Company
With a history of over 30 years and the association to the Commerzbank group, Comdirect maintains a strong presence in the German market. While it is regulated by BaFin, a strong authority, the level of investor protection is relatively low, consistent with German regulations. However, this is mitigated by the fact that the largest holder of Commerzbank is the German state.
Business Profile
Comdirect has established itself as a leading German online broker since its founding in 1994. As a fully-owned subsidiary of Commerzbank AG, it serves over 2.9 million customers with a comprehensive range of banking and investment services. The 2020 full integration into Commerzbank has further strengthened its market position and institutional backing.
Comdirect primarily generates revenue through net interest income (from loans and deposits), fees and commissions (from account services and securities trading), and investment services (brokerage fees). Detailed financials are not publicly disclosed but contribute to Commerzbank’s overall results.
Commerzbank is a leading German financial institution with operations across retail banking, corporate banking, and investment services. In 2023, the bank reported €10.5 billion in revenue and an operating profit of €3.4 billion, with a net income of €2.2 billion. Its primary divisions include Private and Small-Business Customers, Corporate and Investment Banking and Commercial banking. Commerzbank has a market capitalization of approximately €18.7 billion.
Ownership and Transparency
Comdirect operates as a wholly owned subsidiary of Commerzbank, one of Germany’s largest banking groups. Additionally, the bank benefits from its parent company’s strong financial position, reflected in Commerzbank’s BBB+ rating from S&P.
Commerzbank is also classified as a systemically important bank (SIB) in Germany and Europe, due to its significant role in corporate and retail banking, particularly with SMEs. While not a global systemically important bank (G-SIB), it is subject to stricter oversight, higher capital requirements, and resolution planning by German regulators and the ECB under the Single Supervisory Mechanism (SSM). It is also worth noting that the state owns about 15.6% of Commerzbank and that this stake was acquired during the 2008-2009 financial crisis as part of a government bailout, this increases the chances that it would be bailed out in future if it was required. Commerzbank also has institutional investors owning quite a large portion of their stock, while Unicredit recently increased their stake to 28%.
Safety Considerations
Client assets are protected under German and EU regulations, with additional safeguards through Commerzbank’s institutional framework. The broker’s integration with one of Germany’s largest banking groups provides an additional layer of security and operational stability. Commerzbank’s bond rating is BBB+ at S&P and their net profit for the period Jan-Sep 2024 is up 5% at around €1.9 billion.
Regulation & Investor Compensation Schemes
Comdirect is regulated by the German Federal Financial Supervisory Authority (BaFin) and provides investors with a protection amount up to €20,000. Specifically, the scheme covers up to 90% of an investor’s claims, with a maximum limit of €20,000 per investor. This level of protection – while standard among most EU brokers – is considered low. Cash held at Comdirect is protected by the German Compensation Scheme up to €100,000, though it is pooled unless held in your name.
Share & Cash Custodians
Securities are held in ominbus accounts through Clearstream Banking Frankfurt, Germany’s central securities depository.
Cash deposits are held directly with Comdirect Bank AG, benefiting from the full backing of Commerzbank AG.
Reputation
Comdirect has built a strong reputation in the German market over its nearly 30-year history.
In April 2024, Germany’s financial regulator BaFin imposed a €1.45 million ($1.55 million) fine on Commerzbank for breaching anti-money laundering regulations. The violations included failing to update customer data promptly and implementing inadequate security measures, with specific concerns around due diligence in three cases. These issues emerged partly during Commerzbank’s integration of Comdirect. In response, Commerzbank stated it has since reworked its due diligence procedures and completed all necessary data updates by 2022, bringing its operations into compliance with BaFin’s requirements. The fine, split between €375,000 and €1.1 million, reflects Germany’s strict enforcement of banking regulations and represents the most significant recent regulatory action against the bank.
II. Fee structure
Comdirect has relatively low custody fees that can be easily waived. However, its transaction fees are high, making the broker less competitive. Additionally, its foreign exchange (FX) fees are also high.
Platform fees
The custody fee is a flat €1.95 per month (€5.85 per quarter), and it can be waived if you meet certain conditions (such as executing at least two trades per quarter or holding a Girokonto under the same customer number).
However, Girokonto accounts have the following fees:
- Girokonto Extra: basic account for €2.90/month.
- Girokonto Aktiv: include Visa Debit Card and standard banking. It costs €4.90/month, but it is free if you meet one of these conditions:
- €700+ monthly income, OR
- 3 Apple Pay / Google Pay transactions per month, OR
- At least 1 securities transaction per month, OR
- Under 28 years old and a student/apprentice.
- Girokonto Plus: Includes Visa Credit Card, priority support, extra cash withdrawal benefits, insurance €9.90/month
Trading Commisions
- German Exchanges: €4.90 plus 0.25% of trade volume for ETFs, stocks, and other securities
- Non-German Exchanges: €7.90 plus 0.25% of trade volume for ETFs, stocks, and other securities.
- ETF Savings Plans: 1.5% per transaction.
Overall Fee Simulation vs Competitors
Most of our readers have simple Index portfolios. Using our Broker Total cost calculator, you can estimate the total cost of holding ETFs throughout the investment period. For our simulated scenarios, Comdirect comes out as non competitive.
Fee Simulation For General Accounts
The simulation shows Comdirect as the most expensive option, with a total cost of €4,905. The simulation assumes the use of ETF Savings Plans. Consorsbank has €0 cost but this applies only to regular ETF savings plan transactions on the Tradegate exchange. It does not include potentially higher spreads. IBKR has a total cost of €731 but likely lower spreads, so overall cost may be lower.
Investor assumptions
| Model Feature | Assumption |
|---|---|
| Investor | German |
| Instrument | ETF |
| Account | General |
| Initial Investment | € 100,000 |
| Monthly | € 1,000 |
| Time Horizon | 20 years |
| Gross Return | 8% |
Trading Commissions
Currency Exchange fees
Comdirect applies a standard 0.5% fee on all currency conversions for trades in non-EUR denominated securities. This fee is automatically applied to both buying and selling transactions that require currency conversion, effectively meaning a round-trip trade in a foreign currency security incurs a total of 1% in conversion costs. The exchange rates used are based on real-time market rates, with the 0.5% markup being transparently added to the prevailing interbank rate at the time of conversion.
Other fees
The platform charges no account opening fees and waives inactivity fees for the first three years, after which a €1.95 monthly fee applies if one of the following conditions is not met:
- Fewer than two transactions are made per quarter, OR
- Having a linked Girokonto (checking account) with Comdirect, OR
- Executing at least one savings plan (Sparplan) per quarter.
Additional fees may apply for trading on non-German exchanges, though standard SEPA deposits and withdrawals remain free.
Comdirect does not charge a fee for transferring securities to another bank. However, third-party fees may apply, especially for securities held abroad or not cleared through Clearstream. These external fees are passed on to the customer. In some cases, users have reported fees of approximately €2.38 per position when transferring ETFs held abroad.
Finally, Comdirect charges €9.90/month for Premium Research, €19.90/month for real-time market data on non-German exchanges, while basic real-time data is free.
III. Platform & Features
Comdirect offers several features catering to both passive and advanced investors, including a large number of ETFs, Savings Plans, Derivatives and Options. It does not rely on Single Market Maker Exchanges and the cash interest paid for uninvested cash is relatively low.
Account Opening Process
New customers must complete a video identification procedure, which is a regulatory requirement in Germany. A valid German tax ID is mandatory for account activation, and the approval process typically takes 24-48 hours. The broker requires an initial deposit to activate trading capabilities.
account Features
- Custody accounts – Depot, Girokonto and joint accounts.
- CFD trading accounts for more advanced investors.
- Large Range of ETFs including Amundi, Vanguard, iShares and Xtrackers;
- Apps for Android and iOS;
- All Major Stock Exchanges: Nasdaq, Euronext, Xetra, London Stock Exchange (LSE), Zurich, Milan, and 27 international stock markets.
- Customer Service: it is available trough mail, phone and chat although it has mixed review indication room for improvement;
- Intuitive Interface including regular, scheduled investment service.
- Additional tools: price alerts, automated trading and portfolio analysis tools available. They also have advanced charting and real-time quotes for those who prefer to trade more actively. Setting different orders such as limits and stops are also available.
Internalisation and PFOF
Comdirect maintains a transparent approach to order execution, primarily routing orders through traditional exchanges rather than relying on Payment for Order Flow (PFOF) arrangements. The broker executes most trades through XETRA and other lit exchanges, ensuring price transparency and best execution practices in accordance with MiFID II regulations. While some orders may be internalized through Commerzbank’s trading desk for improved liquidity, particularly for larger transactions, this process is clearly disclosed to clients.
Cash Interest
Current interest rate available as at December 2024 is up to 2.8%. The interest is calculated daily and credited to accounts quarterly. It’s worth noting that interest rates are subject to change based on market conditions, and clients can view current rates directly through their online banking portal.
Advanced Features
The platform offers sophisticated tools designed for both casual and professional investors.
Features
| Investment Type | Availability |
|---|---|
| ETFs | ✅ |
| Stocks | ✅ |
| Bonds | ✅ |
| Funds | ✅ |
| Options | ✅ |
| Derivatives | ✅ |
| Futures | ✅ |
| CFDs | ✅ |
| Forex | ✅ |
| Crypto | ❌ |
| Commodities | ✅ (through ETC’s only) |
IV. Taxes
Tax Wrappers
Comdirect supports tax-efficient investing through various tools and services:
- Savings Plans (Sparpläne): Allows regular investments from €1/month in ETFs and funds.
- Capital Gains Allowance (€1,000 per individual, €2,000 for couples): Customers can set up a tax exemption order (Freistellungsauftrag) to benefit from tax-free capital gains up to this limit.
- Flat Capital Gains Tax (Abgeltungsteuer): A 25% tax (plus solidarity surcharge and church tax if applicable) is automatically deducted from investment income.
- Pre-Taxation on Accumulating Funds (Vorabpauschale): Accumulating ETFs and funds are subject to an annual tax on not-yet-realized gains, which Comdirect handles automatically.
Tax Reporting
Consorsbank provides comprehensive tax documents, including annual tax certificates, realized gains/losses statements, foreign tax credit documentation, and capital gains calculations. It also offers quarterly portfolio statements, transaction confirmations, and dividend notifications for streamlined tax reporting.
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