Millions of Europeans Locked Out Of ETFs. Surely, You Must be KIDing?
June 4, 2026
Millions of Europeans Locked Out Of ETFs. Surely, You Must be KIDing?
How a Three-Page Document Locks Millions of Europeans Out of Mainstream ETFs
Last week, I had a coaching session with a High Net Worth client from Athens. He is fluent in English, works in Big Tech, holds a postgraduate degree, and has been investing for a number of years. He wanted to open a broker account with SAXO – a Tier 1 Broker to diversify his Interactive Brokers counterparty risk and buy VWCE – the Vanguard FTSE All-World UCITS ETF that sits at the core of most European passive portfolios.
He could not.
The broker didn’t allow it. The reason is that no Greek-language Key Information Document (known as ‘KID’) exists for VWCE. The broker strictly interprets the regulation requiring a KID in the official language of the investor’s country. Since Vanguard does not publish a Greek KID, the trade is blocked. Not because the product is unsuitable, or because the investor cannot understand it.
But because a three-page disclosure document has not been translated.
It sounds like an easy fix. Why didn’t the issuer bother translating a three-page document? But if it were that simple, it would already be fixed. The real barrier is a chain of three independent failures. And it doesn’t just affect small countries. Yes, investors in smaller countries – Greece or the Czech Republic – cannot access mainstream ETFs, like those from Vanguard. But investors in large countries – France, Italy or Poland – may also not be able to buy niche ETFs, like those from Avantis.
KEY TAKEAWAYS
- Investors in a dozen EU countries are blocked from buying mainstream ETFs from Vanguard. The barrier is a chain of 3 independent failures: Vanguard never registered the fund, the national regulator requires a local-language KID, and the broker enforces that strictly.
- But, the same investor, buying the same ETF, on the same exchange, gets a different outcome depending on which broker they use. Interactive Brokers and Swissquote let a Greek investor buy VWCE. Saxo and DEGIRO block it. Brokers have different setups and attitudes towards litigation risk.
- Workarounds may exist. Consent-based brokers (IBKR, Swissquote, or Lightyear) use English-language consent clauses. For investors with portfolios above EUR 500k (dropping to EUR 250k once the EU Retail Investment Strategy enters force), MiFID II elective professional opt-up removes you from PRIIPs entirely, provided you meet additional conditions. Others like SAXO have a wide enough substitute list to construct a diversified equity portfolio, even without Vanguard.
- The same rule prohibits bigger countries like Italy, France or Poland from buying Avantis ETFs. Brokers may also block investors from bigger countries like Italy or Poland investing in more niche ETFs like those from Avantis, until the issuer registers those locally.
Interestingly, the same Greek investor could open an account at Interactive Brokers and buy the same VWCE on the same exchange, at the same price, within minutes. Or he could use Swissquote. Same investor. Same ETF. Same regulation. The only thing that changes is the broker’s interpretation of a single article in a regulation.
The problem started in 2023, when PRIIPS rules were implemented for ETFs. Unfortunately, this is not a Greek problem, and it is far worse than most investors realise.
WHY INVESTORS IN SMALLER COUNTRIES CAN'T ACCESS VANGUARD ETFs
Problem #1 - The ETF issuer didn't register the ETF
there are 15 countries where VWCE is not registered
Where VWCE is registered
Where Is Your Vanguard ETF Registered?
Before a KID can be translated, the ETF must be registered for distribution in the country. This is a separate step called passporting.
The ETF issuer submits a notification file to its home regulator – typically the Central Bank of Ireland – which transmits it to the host country’s National Competent Authority (‘NCA’). The host NCA charges registration fees, and the issuer must appoint a local facilities agent, translate the KID and key legal documents, and maintain all of this on an ongoing basis, re-translating the KID every time performance scenarios or risk indicators change. For a single country, the annual cost across a full ETF range may run to tens of thousands Euros.
For VWCE, Vanguard has simply never passported into 15 EEA countries, including Greece, Hungary, Romania, Bulgaria, Croatia, Slovenia, Slovakia, and the Baltics. There is no Greek KID for VWCE because Vanguard never submitted the paperwork.
The commercial logic is straightforward. The expected AUM inflow – particularly from financial advisors as registration means the ETFs can be marketed through them – does not justify the cost and hassle.
But why do countries differ in application?
Can you do anything about it? Sometimes. It’s the ETF issuer business logic, although some issuers may be more keen to register the ETF in your country than others. If there is enough demand they may follow the process. For mainstream ETFs, you can try to find equivalent ETFs from issuers that have registered the ETF in your country (e.g. iShares instead of Vanguard)
Problem #2 - INVESTOR'S COUNTRY DOESN'T ALLOW a KID in ENGLISH
Out of those 15 countries, investors in 7 may still be able to buy VWCE
REGULATORY BARRIER
The PRIIPs KID Language Wall
| Country ▲ | VWCE REg.▲ | KID Language Required ▲ | NCA Position ▲ | Barrier▲ |
|---|
investors can trade if A country is strategic or has ties to one of the most spoken languages
What are the rules of the game?
The EU regulation, which is not a directive – so EU states cannot implement it the way they want -is strict:
“The key information document shall be written in the official languages, or in one of the official languages, used in the part of the Member State where the PRIIP is distributed, or in another language accepted by the competent authorities of that Member State, or where it has been written in a different language, it shall be translated into one of these languages.”
In practice, this means:
- Countries like Germany – NCA wants KIDs only in German (see Strict in the NCA column above). The position is strict. But, in practice the country is very strategic to Vanguard and all ETFs get translated, so there is no barrier.
- Countries like Poland or Portugal – NCAs are more flexible, as long as clients sign off a declaration that they can understand English. In practice, Vanguard registered there, but even if it didn’t a broker could still make you declare you understand english and that would do the trick.
But, what about those countries where Vanguard didn’t register the ETF share class you want to buy?
Investors may still be able to buy:
- Cyprus & Malta – thanks to British heritage, the local NCA approved English.
- Countries like Belgium – it turns out the distributing share class is registered so the accumulating class in the table above may de facto qualify as well. If it wasn’t registered at all, the NCA flexibility would still help. Amundi’s equivalent Prime All Country World UCITS ETF (WEBN) is not registered in Belgium, but the local NCA accepts other languages. Amundi already translates KIDs into French and German for neighbouring markets, so the requirement is met without additional effort (and paradoxically non-registration may even mean better TOB tax treatment for Belgian investors).
8 out of 15 countries are too rigid and not strategic enough
We saw that Vanguard also didn’t register VWCE in Iceland, Bulgaria, Croatia, the Czech Republic, Estonia, Greece, Hungary, Latvia, Lithuania, Romania, Slovakia, or Slovenia.
They fall into two camps:
- Not Strategic & Flexible Countries – like Estonia, Iceland or the Czech Republic. NCAs approve KIDs in English on the condition that the broker checks that you understand it. Your local authorities did the right thing giving you flexibility.
- Not Strategic & Inflexible Countries – like Greece, Bulgaria or Slovakia. NCA wants KIDs in local language only, so investors are in a limbo. Local authorities didn’t give you flexibility.
Can you do anything about it? In theory, yes. You may try to pressure local authorities. EIOPA says it is up to each country. Some countries have acted to give investors optionality. Others have not. But, in practice things are more complicated, as we will see shortly.
Problem #3 - BROKERS HAVE DIFFERENT setups & RISK ATTITUDES
illustrative examples
3 categories of brokers (+ Professional opt-in)
How Brokers Handle the KID Language Rule
— Swissquote Bank Europe SA, Securities T&Cs
— Lightyear Terms of Service
- Interactive Brokers (for which EU clients are consolidated into Irish entity under Central Bank of Ireland supervision)
Interactive Brokers 
Swissquote LUXEMBOURG ENTITY
Lightyear
Trade Republic— DEGIRO Help Centre
— SAXO Help Pages
Saxo Bank
DEGIROInteractive BrokersSwissquoteSaxo BankWe examined the customer agreements of few illustrative European brokers to understand how they handle the regulation. The approaches fall into three camps, and the differences are not about regulation. They are about setups and risk appetite – some read it conservatively and block trades, others engineer contractual workarounds that give investors access to the full ETF universe:
- Dealing with you only in English (Interactive Brokers, Swissquote or Lightyear) – brokers may treat a blanket English communication consent as satisfying the language requirement for investors in some countries. Swissquote Luxembourg goes further with a KID-specific clause: if the KID is not available in your language and you proceed to trade, you are “deemed to have understood and accepted” it.
- Dealing with you in your language and in English (e.g. Trade Republic) – some publish bilingual customer agreements and may (or not) include some language about KIDs. For Trade Republic we haven’t found any reference to KIDs language in the English+Greek double-language version.
- Taking a conservative stance (SAXO or DEGIRO) – some enforce the rule very strictly. For DEGIRO, no registration in your country – no trade. It’s not even a matter of KID language. SAXO also mentions the KID translation hurdle in its help pages. Why are some brokers not making a distinction between non strategic flexible and inflexible countries? Perhaps because if they let a Czech investor buy VWCE with an English KID and that investor later loses money, the investor could argue they did not truly understand the risks because the KID was not in their language. The broker is then in a position where they have to defend the adequacy of their language check.
What are the solutions?
In practice, there are alternative ETFs. Czech investors may use e.g. Amundi Prime All Country World UCITS ETF (see all registered countries) or Invesco FTSE All-World UCITS ETF (countries). Greek investors may use iShares Core MSCI World UCITS ETF (countries), or Invesco MSCI World UCITS ETF (countries).
A fourth path exists: MiFID II professional opt-up removes you from PRIIPs entirely. That is the only route that is unambiguously regulator-approved. In this case SAXO will allow an investor to trade any ETF. By mid-2027, the €500k portfolio requirement to become an elective professional client drops to €250k.
Can you do anything about it? Yes and No. You cannot pressure brokers. Brokers have their own risk and business logic. There may have different setups too. But, you can look for brokers that are more flexible.
WHY INVESTORS IN BIG COUNTRIES CAN'T ACCESS NICHE ETFs
ITALIAN, FRENCH OR POLISH INVESTORS MAY NOT BE ABLE TO BUY AVANTIS ETFs
If you followed me until now, you should also understand why a lot of brokers may block investors in bigger countries buying niche ETFs like the Avantis Global Small Cap Value UCITS ETF (‘AVWS’).
AVWS is currently only registered in Switzerland, Germany, Austria, the UK, Denmark, Ireland and the Netherlands.
All other investors are locked out, unless they use e.g. Interactive Brokers.
The same logic applies. Italy accepts only Italian KIDs and until the ETF is registered in Italy brokers may not give access to it. Some brokers may also block e.g. Polish investors to avoid potential litigation risk, even if English is conditionally allowed.
Finally, even if the KID is translated, the ETF may not be automatically available with the broker. For niche ETFs, you may need to request it. Brokers can also be incentivised by ETF providers to promote certain brands more than others. They are the gatekeepers.
We must take a new stance towards cooperation: in removing obstacles, harmonising rules and laws, and coordinating policies. There are different constellations in which we can move forward. But what we cannot do is fail to move forward at all.
What's NEXT?
Our Greek coaching client could use his existing Interactive Brokers account. He could buy VWCE on the same exchange, at the same price, that Saxo blocked him from accessing. But he is likely to prefer a quasi equivalent iShares ETF to diversify away his broker counterparty risk. Here is why he thinks it may be worth it.
Other investors can mix brokers and issuers. Buy Avantis with Interactive Brokers. Use iShares Core MSCI World instead of Vanguard with SAXO. Those with portfolios above €500k (dropping to €250k by mid-2027) can opt up to MiFID II professional status and sidestep PRIIPs entirely.
These are workarounds. They should not be necessary.
A regulation designed to protect retail investors is, in practice, locking millions of them out of building blocks of a diversified portfolio.
Reducing ETF registration cost and burden could help. NCA flexibility especially for very small countries, could also help, but may not be enough for risk-averse brokers.
The real fix is at EU level. Let investors sign off on understanding the risks in any language they understand, as long as a KID is available.
What happens if I spend 10 years in the UK, then move to Greece. I can no longer trade because I may not understand English? We live on a continent where people move across borders, speak multiple languages, and use AI to translate a three-page document in seconds. As Draghi put it, “what we cannot do is fail to move forward.”
This seems like an easy place to start.
What else should you consider?
In the upcoming guide, we will look at broker tax reporting. Which ones gives you hassle-free tax submissions?
Good Luck and Keep’em* Rolling!
(* Wheels & Dividends)
