ELTIF definition, functioning, marketThe reference work 2026

Time to read13 min.

updated at06/10/2026

CategoryELTIFs

Access road with wind turbines at the Moanvane Wind Farm.

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The ELTIF (European Long-Term Investment Fund) opens up long-term investments in tangible assets for private investors. Here you will find structured answers to all relevant questions, from the basics to the current market development in 2026.

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Chapter One: ELTIF fundamentals

What is an ELTIF?

An ELTIF is a format for investment funds that applies to all EU Member States and allows retail investors to invest in tangible assets and the real economy over the long term. The abbreviation stands for “European Long-Term Investment F and”. Investments are made in areas that need a long breath, such as infrastructure, renewable energies, real estate, small and medium-sized enterprises, private equity or private debt.

What distinguishes the ELTIF from traditional public funds is its purpose. Equity or bond funds replicate the financial markets. An ELTIF, on the other hand, finances real projects, from wind farms to electricity grids and SME loans.

This is regulated in a separate EU regulation that came into force in 2015 and was significantly revised in 2024 with the ELTIF 2.0. Strict diversification, transparency and risk management requirements are designed to ensure that retail investors receive a reliable investment product.

From a market perspective, this design has proven its worth. By the end of 2025, the assets managed in ELTIFs grew to around 34 billion euros, spread over at least 268 funds. In 2025 alone, 113 new ELTIFs were added¹. This means that the ELTIF is still a young instrument, but no longer a niche product.

How did the ELTIF come about?

The ELTIF is a creation of the European Union. With Regulation (EU) 2015/760 of 29 April 2015, the EU created a single framework for long-term investment funds that can be marketed throughout the Union. The Regulation entered into force on 8 June 2015 and became applicable in all Member States on 9 December 2015.

The goal was clear from the outset: Private capital should flow into the European real economy in the long term, in infrastructure as well as into SMEs. In practice, however, the instrument remained below expectations in the first few years due to the high entry hurdles for retail investors and the narrow scope of eligible assets. From Germany, klimaVest in particular caused a lot of attention even before the reform. Launched in 2020, the ELTIF from Commerz Real is still by far Europe’s largest ELTIF².

The actual turnaround came with the ELTIF reform. On 15 February 2023, the EU adopted a revised regulation known as ELTIF 2.0, which came into effect on 10 January 2024. The final regulatory technical standards published in the EU Official Journal on 25 October 2024 (Delegated Regulation (EU) 2024/2759) then took the decisive step towards practical impact. It is only from this date that the ELTIF in its revised form is fully operational, and it is precisely since that time that the market has picked up significantly.

Why do we need an ELTIF?

Europe is facing tasks that cannot be financed by traditional means. Switching to renewable energy and maintaining a high-performing infrastructure are just two examples. Such projects are essential for Europe’s future viability and require capital of a magnitude that banks and institutional investors alone cannot raise.

Elsewhere, the capital for this was certainly available, saving European households. But private investors lacked access. Those who wanted to participate in such large-scale projects had hardly any suitable investment products available before 2015. Added to this was the fragmentation of the European financial market. National financial instruments were inconsistent and rarely long-term, making cross-border investments even more difficult.

This is where the EU came in: Why shouldn't the savings available go to exactly those projects that Europe needs anyway? In 2015, the ELTIF created a vehicle that directly connects private capital and the real economy, with a uniform framework and an EU-wide distribution passport. The Brussels agenda shows that the task will not get smaller. In March 2025, the European Commission presented the Savings and Investment Union to further direct private capital into the European real economy.³

What are the objectives of the ELTIF?

The ELTIF aims to direct private capital where it is needed in the European real economy in the long term. In concrete terms, this means:

Renewable energy and electricity grids
Transport and utility infrastructure
Digital infrastructure and telecommunications networks
Small and medium-sized enterprises as the backbone of the European economy
Socially relevant buildings such as schools, hospitals or care facilities
Investments and loan financing of non-listed European companies (private equity, private debt)

Unlike traditional investment products, the money goes directly to these projects. It flows into the respective projects and thus into the real economy via the capital management company. This direct investment character is what makes the ELTIF a stand-alone instrument in the EU strategy.

The ELTIF is politically embedded in the European Green Deal and the Capital Markets Union, both of which aim to concentrate investments in Europe more strongly and to align them more sustainably. The Savings and Investment Union, presented by the European Commission in March 2025, consistently continues this line: Private savings should flow even more into those projects that keep Europe fit for the future.³

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Chapter Two: Functionality and regulations

How does an ELTIF work?

An ELTIF is an investment fund that pools the money of many investors and invests together in tangible assets and long-term projects. Anyone subscribing for shares does not pay directly into a holding, but into a fund that is legally separate from the fund company’s assets. Investments are made from this fund. This means that the basic idea behind an ELTIF is the same as that of classic funds: Many small amounts become a large one, which can be used to make investments that would not be accessible to an individual person.

The difference lies in the objective of the investments. While equity funds invest in listed companies or bond funds in government and corporate bonds, an ELTIF directs capital to real projects, such as the construction of wind farms, electricity grids, SME investments or infrastructure loans. At least 55 per cent of the fund assets must flow into such eligible investments in accordance with EU requirements. The remaining 45 percent may be held in more liquid investments to manage redemptions or new investments.⁴

Income arises from current income from investments, i.e. rent, interest or electricity revenue, as well as from the subsequent sale of individual investments. These return flows flow back into the fund assets. For investors, they come in two ways: on the one hand through regular distributions during the term, on the other hand through the sale of the units, whether during the term through redemption windows or at the end of the fund term through the payment of the remaining assets.

How is the value of an ELTIF calculated?

The value of an ELTIF is determined by the so-called net asset value, or NAV for short. It is equal to the Fund’s assets less its liabilities divided by the number of units issued. This value is the price per share used for issue, redemption and reported performance.

Unlike an equity fund, an ELTIF is not necessarily valued on a daily basis. How often the NAV is calculated depends on the fund model. Under German law, closed-ended ELTIFs must determine their value at least once a year. Semi-liquid or evergreen ELTIFs that offer redemptions during the term usually value quarterly or more frequently, because the valuation logic must be based on the redemption frequency according to the final technical standards of October 2024.⁵ Some of the fund assets cannot be valued using day-to-day market prices because wind farms, electricity grids or SME holdings are not traded like a share. Therefore, ELTIFs work with internal valuation guidelines and rely on external opinions or model valuations for illiquid assets.

For investors, the NAV is the price anchor. When buying shares, the issue price is based on the share price, and when redeeming shares, it is used as the basis for calculating the payout amount. It is important to note that: A published NAV does not automatically mean that shares can be sold at any time at that value. ELTIFs are subject to redemption rules that are different from a traditional open-ended fund. We will discuss how this mechanism works in detail in the chapter on liquidity.

Why is an ELTIF so highly regulated?

With the ELTIF, the EU opens up access to investments that were previously only open to institutional investors for private investors. This opening requires its own protection regime. What is collected by insurance companies or pension funds via internal risk departments and large diversification must be taken over by the regulation itself for private customers. This is precisely why the ELTIF works with a tight set of rules, which have been partly further tightened and partly simplified with ELTIF 2.0 and the final technical standards of October 2024.

Three rules have a particularly direct impact on investors:

Diversification: A maximum of 20 percent of the fund assets may be invested in a single investment. No single project or company can dominate the fund.
Clearly defined investment universe: Only tangible assets, infrastructure, investments and loan financing of a long-term nature are permitted. Speculative strategies such as short selling or commodity betting are excluded.
Limited debt financing: An ELTIF distributed to retail investors may finance a maximum of 50% of its net asset value with debt capital, which prevents excessive leverage risks.

In addition, each ELTIF is reviewed by the competent supervisory authority before it is launched, in Germany by the BaFin. The European Securities and Markets Authority (ESMA) maintains a public register of all authorised ELTIFs.

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Why are so many ELTIFs authorised in Luxembourg?

Luxembourg offers ELTIF providers better conditions than any other EU location: fast and experienced supervision, established structures for Europe-wide sales and the necessary specialists directly on site. For a fund that is by definition European-oriented, this is the obvious choice.

This can be seen in the figures. Luxembourg is the largest fund location in Europe and the second largest in the world after the USA, with a fund volume of around 7.4 trillion euros by mid-2025. This position is also clear for ELTIFs: Out of 116 ELTIFs domiciled across Europe, 80 are registered in Luxembourg and out of the 55 new authorisations in 2024, 37 were in Luxembourg.⁷

Behind this concentration are three concrete benefits:

Efficient supervision: The Luxembourg CSSF specialises in funds and is considered to be swift and competent in approving new products.
On-site specialists: Banks, custodians, auditors and law firms with fund experience are close together in Luxembourg. This significantly speeds up the launch and ongoing operation of a fund.
EU Passport: An ELTIF authorised in Luxembourg may be marketed throughout the EU without the need for additional national authorisation.

The fund location does not say anything about where the money is invested. An ELTIF authorised in Luxembourg can invest in German wind farms or Spanish solar projects in the same way as a fund authorised in Germany. klimaVest is also part of this. The fund is established in Luxembourg, but directs its capital across Europe into tangible assets for the energy transition.

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Chapter Three: Comparison of ELTIFs and other fund types

How is an ELTIF different from an UCITS?

The main difference lies in the permissible systems: A UCITS fund invests in liquid securities such as equities and bonds, while an ELTIF invests in long-term tangible assets and the real economy. UCITS (Undertakings for Collective Investments in Transferable Securities), in German UCITS (Undertakings for Collective Investmentsin Transferable Securities), is the European umbrella term for investment funds that invest in legally defined securities. In particular, shares, bonds, money market instruments or units in other UCITS funds are permitted here. Anyone who owns a classic equity or bond fund therefore almost always holds an UCITS fund. The ELTIF has adopted many of these rules, particularly with regard to investor protection, but opens up additional investment areas.

It must invest at least 55 percent of its assets in investments outside the pure securities world, i.e. in tangible assets, infrastructure, SME investments or loan financing. The remaining up to 45 percent may be held in more liquid UCITS-capable investments in order to control movements in the fund.

This results in different character traits. UCITS funds are generally traded on a trading day and are valued equally often. The market price shows the current value at all times. In the case of an ELTIF, the Net Asset Value (NAV) is often calculated less frequently and serves only as a guideline, not necessarily as a selling price. When and at what price investors can actually exit depends on the form of the ELTIF and is regulated in the fund prospectus.

Both constructs are strictly regulated and marketable across the EU, but they complement each other rather than being excluded. UCITS represent the liquid world of securities, while ELTIFs open the door to the real economy. Both can fit into an investor’s portfolio if the respective investment objectives fit together.

How is an ELTIF different from an Alternative Investment Fund (AIF)?

There is no real difference, because an ELTIF itself is an Alternative Investment Fund (AIF). AIF is the collective term for all investment funds that do not belong to the UCITS family. Within this world of AIFs, there are different subcategories such as open and closed AIFs or public and special AIFs. The ELTIF is not a separate fund type, but an additional EU authorisation that an existing public AIF receives if it meets the requirements of the ELTIF Regulation.

In practice this means: Every ELTIF is an AIF, but not every AIF is an ELTIF. ELTIF authorisation entails additional EU-wide rules, such as on permitted investments, diversification and investor access. In return, an ELTIF may be marketed throughout the EU, whereas a “normal” German AIF generally remains restricted to the German market.

How is an ELTIF different from a closed-end fund?

A classic closed-end fund has a fixed term in which the capital is tied up and redemptions are not possible in principle. An ELTIF can also be set up as a closed-ended fund, but since ELTIF 2.0 it can be constructed in the same way as a semi-liquid or evergreen structure. Which form a specific fund chooses is a decision of the fund management company at the time of launch.

The ELTIF is therefore not the counterpart to the closed fund, but the more flexible format that contains the closed form as one of three options.

There are also legal differences. Classic closed-ended funds in Germany are usually structured as closed investment limited partnerships, with national BaFin authorisation and without an EU-wide distribution passport. An ELTIF, on the other hand, is an EU-wide harmonised product that can be marketed throughout the Union once the regulatory authority in the country of domicile has granted authorisation.⁸

How is an ELTIF different from an ETF?

Despite the similar letter sequence, ELTIFs and ETFs are two very different investment products. The Frankfurter Allgemeine Sonntagszeitung formulated it accurately in April 2026: ELTIFs are “the exact counterpart to index funds in many ways”.⁹

An ETF (Exchange Traded Fund) usually passively tracks an equity or bond index such as the DAX or the MSCI World and is traded like a share on the stock exchange. An ELTIF, on the other hand, actively invests in tangible assets and long-term projects in the real economy, is not listed on the stock exchange and follows its own return mechanism.

This results in two noticeable differences for investors:

Liquidity: ETF shares can be bought and sold in seconds on a trading day, while an ELTIF can only be redeemed during specified windows and with advance notice.
Price setting: In the case of an ETF, the current value can be read at any time on the stock exchange price, while in the case of an ELTIF, the value is calculated less frequently and is partly based on model valuations of the underlying tangible assets.

ETFs and ELTIFs do not exclude each other in the custody account, they complement each other. ETFs cover the liquid, exchange-traded world inexpensively and transparently. As a portfolio addition, ELTIFs open the door to long-term tangible assets and return opportunities beyond the stock market that are structurally missing in a pure ETF portfolio. In addition, the right ELTIF largely stabilises the custody account against typical stock market fluctuations

How is an ELTIF different from an open-ended real estate fund?

The main difference lies in the breadth of the asset classes. An open-ended real estate fund invests exclusively in real estate, i.e. office buildings, shopping centres or residential complexes. While an ELTIF can also hold real estate, it is broader. Renewable energies, electricity grids, SME loans or infrastructure are just as much part of the possible investment universe.

Open-end real estate funds are much more established on the German market. With around 284 billion euros of assets under management at the end of 2024, they are virtually part of the mandatory program for many investors in the custody account, because real estate has been set as a stable tangible asset component for decades. This is precisely where ELTIFs come in. They make it possible to further increase the tangible value share in the custody account without playing the property card that is already represented even more strongly. Anyone who is already invested in open-ended real estate funds gains additional tangible asset diversification with an ELTIF across sectors such as the energy transition or infrastructure.¹⁰

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Chapter Four: ELTIF Forms

What form of ELTIFs are there?

Three basic forms characterise the ELTIF market:
•    Closed-ended funds with a fixed term
•    Semi-liquid ELTIFs with fixed-term redemptions
•    Evergreen ELTIFs with no fixed maturity

Until the 2024 reform, the closed form was the normal case, but the market leader klimaVest was designed as an open-ended fund from the outset. Since ELTIF 2.0 and the final technical standards of October 2024, there have been clear rules for all three forms. Previously, they were largely missing for the open variants.

In a closed-ended ELTIF, capital is tied up over the entire term. Shares cannot in principle be redeemed during this period, the money will only return for liquidation at the end. This form remains useful for investments where it takes years before they can generate income or be resold. Practical examples could be a new port, a new hospital or a tunnel. The Gotthard Base Tunnel, for example, had a construction period of 17 years before the first train travelled and revenues were possible.

Semi-liquid ELTIFs open the model for redemptions at fixed windows, typically quarterly or semi-annual. To make this work, they hold part of the fund assets in more liquid investments. 15 to 30 percent is common on the market.¹¹

Evergreen ELTIFs are the game without a fixed maturity date and are open to new investors on an ongoing basis. As a rule, they are held in semi-liquid form at the same time, which is why both terms are often used synonymously on the market. In more detail, Evergreen describes that the fund has no maturity. Semi-liquid describes that and how it redeems shares.

In addition to these basic forms, other structures have established themselves since the reform. Umbrella ELTIFs invest in other private market funds, thus creating additional diversification. Multi-asset ELTIFs bundle multiple private market classes such as private equity, private debt and infrastructure into a single fund

In which asset classes do ELTIFs invest?

ELTIFs invest in four major off-exchange asset classes. Sonja Knorr from the Scope analysis company sees this as the main opportunity for private investors: "ELTIFs offer extensive investment opportunities, the keyboard is very extensive. This can help to diversify one’s own assets more widely."⁹ As at the end of 2025, the total volume on the ELTIF market is distributed as follows:¹

Private debt: 34 percent
Infrastructures: 28 percent
Private equity: 19 percent
Other, mainly real estate and multi-asset: around 16 percent

Behind private debt are loans to European companies that do not run via banks or bond markets. This class has been by far the largest in the ELTIF market since 2024, as many SMEs have shifted more towards alternative financiers in recent years.

Infrastructure includes both energy projects such as wind farms, solar panels and electricity grids, as well as transport infrastructure, water and telecommunications networks. This class benefits from long-term contracts, predictable returns and political support from the European Green Deal. klimaVest is Europe’s largest ELTIF and invests primarily in infrastructure for renewable energies.

Important reminders: Where “infrastructure” is written, infrastructure is not always in the narrower sense. The term is broadly understood in ELTIF prospectuses, and infrastructure investments may also include assets that have little to do with what investors traditionally associate with them, depending on the provider. For example, helicopters for fire-fighting were behind an investment designated as infrastructure - certainly not what many people first think of as infrastructure.¹²

Before buying, it is therefore helpful to look at the prospectus and annual report to understand what is really in the portfolio. At Commerz Real, klimaVest and infraVest form two products whose investment priorities are transparently identified: renewable energies and electricity grids at klimaVest, broader German infrastructure at infraVest.

Private equity means holdings in unlisted companies, often medium-sized market leaders in Europe. Investors become co-owners here and participate in the increase in the value of these companies.

Real estate is rather the smaller class in the ELTIF universe because it is already well covered via (open-ended) real estate funds. ELTIFs often focus on social issues, such as schools, clinics or care facilities.

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General views

The four ELTIF asset classes with possible assets

Private debt: Direct loans to European companies outside the traditional banking channel, such as SME financing, acquisition financing or growth loans
Infrastructure: Wind farms, solar power plants, electricity grids and power plants, as well as airports, ports, toll roads, waterworks, waste disposal and telecommunications networks
Private Equity: Investments in unlisted companies or listed small and medium-sized enterprises (SMEs) up to a market capitalisation of EUR 500 million (according to the ELTIF Regulation)
Properties: Social properties such as schools, clinics or care facilities

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Where do ELTIFs invest?

Where an ELTIF invests depends on its investment strategy and is set out in the Fund’s prospectus. Three basic patterns can be observed on the market:

ELTIFs that invest their money exclusively or largely in the EU
ELTIFs investing in Europe and additionally in the US or other developed countries
ELTIFs that specifically invest outside Europe

Important reminders: The name component “European” in ELTIF refers to the rules and regulations, not to the investment region. Only a few ELTIFs focus fully on Europe. Some, for example, rely on sub-Saharan solar power - including all political risks.¹³

Before buying, it is therefore helpful to look at the prospectusto understand where the capital is actually being invested. klimaVest has deliberately opted for a purely European strategy and invests exclusively in renewable energy plants within the EU, spread over 44 locations in 6 (excluding Luxembourg) countries.¹⁴

What are the benefits of operating across Europe as an ELTIF?

The EU-wide diversification allows an ELTIF to take advantage of different market dynamics in different countries and regions and reduce cluster risk. ELTIF is a financial instrument designed by the EU and thus made available to all EU countries. Like most investment instruments, ELTIFs also benefit from the widest possible diversification, particularly geographically.

For example, by investing not only in Germany, but also in Spain or Sweden, a German ELTIF can make use of very different market potentials and dynamics, which contribute to greater risk diversification.
This is particularly evident in the area of renewable energies: For example, in Finland, wind farms are used primarily, while in southern EU countries such as Spain, solar power technologies are mainly used.

The key word here is diversification: The EU-wide diversification of assets can avoid a cluster risk that would result from concentrating on only one or a few renewable energy production sites.
By including assets from different countries in an ELTIF, not only geographical but also technological diversification is achieved. If electricity production in a region declines temporarily due to weather conditions, this backlog can be offset by investments in other technologies and countries.

In addition, the EU offers a reliable regulatory framework and sufficient political and economic stabilityto successfully implement both renewable energy investments and corresponding investment products such as ELTIFs in the long term. With the European Green Deal and the Savings and Investment Union, which the European Commission presented in March 2025, this line is further secured politically.

In the case of the ELTIF klimaVest, the EU-wide diversification of assets has long proven its worth: With currently 43 wind and solar power plants in 6 (excluding Luxembourg) countries, the fund aims to achieve as stable and continuous electricity production as possible and to minimise the risk of failure. Technological and geographical diversification contributes significantly to this. The diversification also pays off for investors, as it ensures lower investment risk and greater planning certainty.¹⁴

What does ELTIF 2.0 mean?

ELTIF 2.0 is the reform of the 2023 ELTIF Regulation, which has been applicable since January 2024 and has made the instrument significantly more accessible to retail investors. It removes key hurdles that had hampered the growth of the ELTIF market in the first few years and adapts the rules to the reality of long-term investments in tangible assets.

An overview of the most important changes:

Elimination of the minimum investment of EUR 10,000 and the 10% asset limit previously applicable to private investors
Reduction of the minimum private market quota from 70 to 55 per cent, allowing ELTIFs to also hold more liquid components
Increase of the diversification limit from 10 to 20 per cent per individual investment
Increase of permitted debt financing in retail sales to up to 50 percent of the net asset value
Returns and matching mechanisms established as regular product option during the term

In practice, the reform only became effective with the final technical standards of 25 October 2024 (Delegated Regulation (EU) 2024/2759). Since then, the market has noticeably picked up. By the end of 2025, the assets managed in ELTIFs grew to around 34 billion euros, with 113 new ELTIFs added in 2025 alone.¹³

A detailed presentation of the reform with detailed regulations and a comparison table can be found on the ELTIF 2.0 page.

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Chapter Five: Liquidity and return in ELTIFs

How liquid are ELTIFs?

In terms of liquidity, ELTIFs lie between equity funds and classic closed-end funds. They are not as freely tradable as an ETF, but also not as rigid as a closed-ended equity fund, which fully ties up capital until maturity.

ELTIFs are also not their own liquidity category, but rather a regulatory framework. The liquidity profile offered by an individual fund depends on how the fund management company has constructed it. Closed ELTIFs generally do not allow redemption before maturity, while semi-liquid and evergreen ELTIFs open redemption windows on fixed dates. Sonja Knorr from Scope puts it succinctly: ELTIFs are “less transparent and less negotiable than equities, bonds or index funds, for example”.⁹

The Stiftung-Warentest study of 29 ELTIFs sold to private investors in Germany from April 2026 shows how far the spectrum extends: Many funds have a minimum holding period of up to three months, and another group has a holding period of up to eight years. Some funds do not accept redemption at all before maturity. Only klimaVest has so far had no minimum holding period.¹³

What does semi-liquid ELTIF mean?

Semi-liquidity is a market term for funds that are not freely payable in and out on a daily basis, but are also not completely locked up until maturity. Investors can therefore exit before the end of the term, but only on fixed dates and under certain conditions.

The term is not included in the ELTIF Regulation, but describes exactly the model that the Regulation allows in Article 18. In concrete terms, semi-liquid means: Redemptions only take place in windows, with lead times and often minimum holding periods, and the Fund may limit or temporarily suspend redemptions if too many investors wish to exit at the same time.

For the model to work, a semi-liquid ELTIF holds part of its assets in more liquid investments such as overnight money, money market securities or UCITS funds. 15 to 30 percent is common in the market for evergreen ELTIFs. This reserve allows the fund to serve redemptions without having to quickly sell assets such as wind farms, solar panels or company holdings, which would hardly be possible in the short term for such assets.¹¹

But beware: Semi-liquid does not mean “almost liquid”. Experts expressly warn against confusing semi-liquid ELTIFs with daily traded funds. The term describes the possibility of return, not its guarantee. Only return windows, lead times, limits and suspension rules make a fundamentally illiquid investment in tangible assets a semi-liquid product.¹¹

What are the deadlines for ELTIFs?

For ELTIFs, there is not one deadline, but three different ones that work together.

Minimum holding period: Period after purchase during which units cannot be redeemed at all.
Notice period (Notice Period): Period between registration of the return and payment.
Return window: fixed dates on which the Fund accepts redemptions at all.

The ELTIF Regulation does not set rigid values for this. It sets out in Article 18 only the framework within which the Fund Management Company may set the three deadlines. A quarterly frequency for return windows has become established as the market standard. Monthly or more frequent appointments are possible, but must be justified to the supervisor.¹⁵

How different the deadlines on the market are, shows the Stiftung-Warentest study of 29 ELTIFs sold to private investors in Germany from April 2026. For many funds, the minimum holding period is three months, for another group it is up to eight years. Some ELTIFs only allow redemptions at all at the end of the term. klimaVest makes an exception here: no minimum holding period and no lead time for redemptions up to EUR 500,000 per year. A twelve-month notice period applies only after this date.¹⁶,¹³

Before purchasing an ELTIF, it is therefore advisable to take a look at the key information document. There, all three deadlines are compactly arranged next to each other.

Are ELTIFs tradeable on a daily basis?

No, usually not. ELTIFs are not listed and follow their own redemption mechanism with fixed dates. Anyone buying an ELTIF should therefore assume that units are not available for sale at all times.

For most ELTIFs in the market, redemptions are possible once per quarter, often with several weeks lead time. Daily returns, on the other hand, are the exception. klimaVest is one of the few funds that can be traded on a daily basis. Investors can redeem their shares relatively easily, for amounts up to EUR 500,000 per year without notice period and without minimum holding period. Higher amounts are subject to a twelve-month notice period and the total amount of all redemptions per Valuation Day is limited to 50% of the Fund’s liquidity investments. In the Stiftung-Warentest study of 29 ELTIFs marketed in Germany, klimaVest is the only fund without a minimum holding period.¹⁶

It is not possible to sell ELTIFs on the stock exchange. Although individual platforms such as Trade Republic organise intra-vendor trading between their own customers, this does not result in a guaranteed redemption.¹⁷

How does the redemption of ELTIF shares work?

The redemption of ELTIF shares takes place in four steps:

Login Throw Investors report their redemption to the Fund within the specified lead time.
Verification: The Fund checks whether the minimum holding period and redemption limit are complied with.
Price setting: The redemption price is determined on the basis of the current unit value.
Disbursement: The amount will be transferred within the period stated in the Fund’s prospectus.

Specific lead times and limits can be found in the relevant fund’s key information document.

The return limits are the most important protection mechanism. They prevent the fund from having to sell too many assets at the same time under stress. It is common to limit this to a percentage of the fund assets or liquid reserves. If the sum of all redemption requests exceeds this limit, the Fund may serve redemptions pro rata or temporarily suspend redemptions. This suspension is called a gate.

What happens at the maturity of an ELTIF?

At the end of the term, the Fund will end. This means that The Fund Company begins to sell all assets and distributes the proceeds pro rata to investors.

How long this takes depends on the assets. A company investment cannot be sold in weeks, and an offshore wind farm certainly cannot. The Fund Management Company therefore generally has the right to extend the term twice, each time by a few years, if the orderly sale takes more time. Investors then receive their money back staggered over time, depending on when which assets are sold.

Evergreen ELTIFs do not have a fixed maturity. They are committed to continuing to run for the long term. Investors exit through the regular redemption windows, not through the dissolution of the fund.

klimaVest is designed as an open-ended fund, with a planned term of 50 years until 2070 and the option to extend twice by five years each.¹⁸

Is there a secondary market for ELTIFs?

There is currently no functioning, widely established secondary market for ELTIFs. Shares cannot be sold via Xetra or another exchange because ELTIFs are not listed on the stock exchange. Those wishing to exit rely on the fund’s regular redemption windows.

There are initial attemptsto bring exit-willing investors directly together with new investors, for example via provider-internal platforms of individual neobrokers. Whether such models will prevail in practice remains to be seen.

What investment horizon should you bring with you for an ELTIF?

ELTIFs are long-term investments. Anyone buying an ELTIF should have an investment horizon of at least five years, significantly more for some funds.

The providers’ recommendations reflect the logic of the assets. An offshore wind farm, a holding in a medium-sized company or an infrastructure asset develops its value over many years. If you exit earlier, you risk missing out on the high-yielding years in particular or having to sell at an unfavourable time.

The recommended holding periods vary widely in practice. Most ELTIFs name five years, individual funds last up to 20 years. Some only accept returns at the end of the term. klimaVest recommends a holding period of more than five years.¹⁶,¹³

The long-term view of ELTIFs as an investment form is also evident from a political perspective. From 2027, ELTIFs are to be authorised for the planned retirement deposit. Anyone considering ELTIFs should therefore consider them as a long-term addition to the portfolio, not as a reserve for short-term needs.²

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Chapter six: Return and risk of ELTIFs

What return opportunities do ELTIFs offer?

ELTIFs offer return opportunities between 3 and 14 percent per year.¹¹ However, the high figures are usually target returns that providers communicate in marketing documents, unrealised performance. To date, no ELTIF has demonstrated double-digit returns in a multi-year, audited track record for retail investors.

klimaVest, Europe’s largest ELTIF, provides concrete figures: medium to long-term target return of xyz percent per year, adjusted to 3 to 4 percent for the current financial year 2025/26. In financial year 2024/25, the fund achieved a performance of 3.5 percent, while it stood at 3.7 percent in financial year 2023/24. klimaVest has recorded positive performance in each financial year since its 2020 launch. This scale is more realistic for tangible ELTIFs that derive their income from current contractually hedged cash flows.¹⁹

The market across the asset classes looks like this¹¹:

Private debt: typical interest rates in the range of 5 to 7.5 percent, which compensate for an increased default risk of the financed companies.
Infrastructure: in the moderate single-digit range. The higher the target return, the more it depends on debt capital or narrow diversification.
Private Equity: Target returns usually in the high single-digit to low double-digit range, i.e. around 9 to 14 percent per year. This increases the risk accordingly and the investment is only suitable for experienced investors.
Multi-Asset: Mixed forms that lie between the individual modules depending on their weighting.

The return that a specific ELTIF can deliver depends on several factors. “The asset class in which the fund invests, as well as the investment conditions and the leverage ratio, i.e. the debt capital share, play a particular role,” says Axel Seider, product developer of klimaVest at Commerz Real. Added to this is the logic of the underlying tangible assets: The return is distributed over the investment period, which is clear from the example of an investment in renewable energies. The risky development period of a wind farm is only about 1.5 years, after which the asset is held with significantly lower risk for 10 to 15 years and delivers steady income from ongoing electricity sales.

Caution is warranted with regard to the high target returns. A concrete example from the Stiftung-Warentest comparison: An ELTIF with a solar focus reported an annual return of 15.8% at moderate risk in the key information document in the “medium scenario”. Upon request, the provider itself described this figure as unrealistic and stated 5 to 6 percent as realistic over the entire term.¹³

Scope analyst Sonja Knorr therefore recommends investors to select providers with a strong history⁹ - i.e. houses that have proven their strength even in difficult market phases.

How safe are ELTIFs?

ELTIFs are strictly regulated investment funds with extensive investor protection. However, how safe a specific ELTIF actually is depends heavily on its asset class. An infrastructure ELTIF with stable renewable cash flows has a significantly different risk profile than an ELTIF that invests primarily in private equity or private debt. Common to all ELTIFs is the long-term nature and illiquidity of the investments. Those who cannot hold their money in illiquid securities for several years should therefore switch to more liquid fund formats.

The risk indicator of a fund depends on its strategy and structure. In the product description, the value is given on a scale between 1 (low risk) and 7 (higher risk). It indicates how likely it is that money will be lost because the market is performing differently than expected or the manager is not able to pay out to investors.

The classification is made by the fund providers themselves. It is therefore advisable not to rely solely on a risk class. In the case of ELTIFs, the main considerations are the assets in which the investment is made, as well as product characteristics, market conditions and, where applicable, other risk factors.

Conservatively oriented ELTIFs invest in assets with stable, often contractually hedged cash flows such as infrastructure, renewable energies or socially relevant real estate. These are less cyclical than investments that follow the economic cycle and are more long-term than most other offerings. In accordance with the ELTIF Regulation, borrowing is limited to 50 per cent of the net asset value of an ELTIF sold to retail investors, which reduces the leverage risk. Due to the European focus, there is generally also less country risk. ELTIFs in asset classes such as private equity or private debt, on the other hand, carry a higher default and concentration risk.

For example, the ELTIF klimaVest is managed in the risk class 1 of 7, as it is long-term invested, invests in fundamentally stable asset classes (mainly renewable energies), its debt capital ratio is very limited and it is managed as an open-ended fund.²⁰

As is customary for funds, an ELTIF also carries the risk of a partial or total loss of the capital invested. This is unlikely, although possible, for example if all the assets held by the fund perform poorly because, for example, the global economy collapses or completely unforeseen laws are passed. Despite extensive currency hedging, a residual currency risk also remains.

Things to consider:

How diversified is the fund? Larger funds are often, but not automatically, broader. It is worth taking a look at the number and spread of individual systems.
What type of investments does the fund invest primarily in and how risky are these to be assessed? Investments in power plants using fossil fuels such as oil or coal are no longer considered technologies of the future. Mobile assets such as aircraft and ships are cyclical and therefore more risky, whereas immobile assets such as power grids or solar parks are independent of cycles.
How secure do the income from business operations or the business model of the assets appear?
How experienced is the fund management in the management of the portfolio assets?

What are the risks of ELTIFs?

The main risks of an ELTIF are the limited liquidity, the periodic valuation of investments, a narrower diversification spectrum compared to ETFs, high and multi-layered costs and the reliance on the experience of the fund management. There are also market and interest rate risks for the respective asset class.

The extent to which these risks are reflected in the specific fund depends heavily on the asset class. An infrastructure ELTIF with renewable energy and contractually hedged cash flows has a different risk profile than a private equity ELTIF with holdings in high-growth but uncertain companies. The following risk types characterise the market in 2026:

Liquidity risk: Shares cannot be sold on a trading day. For semi-liquid ELTIFs, the redemption is tied to deadlines and windows, and in the event of stress, the fund may suspend redemptions.
Valuation risk: Some of the fund assets are not valued using market prices, but using models and opinions. Stable NAVs may obscure actual fluctuations.
Concentration risk: An ELTIF may invest up to 20 per cent in a single investment and must hold at least five properties. This is significantly less spread than for an ETF on the MSCI World with over 1,300 ²¹
Manager and reputational risk: The quality of fund management is difficult for private investors to assess. In a 2025 Scope survey, 34% of vendors named the reputational risk posed by inexperienced managers as one of the biggest industry hazards.²²
Expenditure: Ongoing fund costs are around 1.9 per cent per year on market average and can reach three per cent or more for private equity strategies. In addition, there are often performance fees and an initial charge of up to five percent.¹
Market and interest rate risk: ELTIFs are also not decoupled from the economy. Higher interest rates are putting pressure on the valuations of infrastructure projects, for example, while economic weaknesses increase the risk of default in private debt.

Against this background, ELTIFs are generally seen as an addition to the portfolio, typically between 5 and 10 percent of the assets. Sonja Knorr from Scope mentions 10 percent as a sensible upper limit. It is in this order of magnitude that their actual strength lies. A well-designed ELTIF can balance a highly equity-driven custody account with the stability of long-term tangible assets.¹¹

Before purchasing, it is worth looking at four points: investment horizon, costs, investment strategy and reputation of the fund management. To date, double-digit target returns that individual providers use to advertise have primarily been model forecasts. The majority of these ELTIFs were launched in 2024 or 2025 and do not yet have a multi-year track record against which the promises could even be measured.

Can ELTIFs make my portfolio more independent of the stock market?

With an appropriately constructed ELTIF: yes. How the fund generates its income is crucial. The ELTIF klimaVest, for example, invests primarily in wind and solar farms as well as electricity grids in Europe. It thus generates its income through long-term electricity purchase agreements and regulated feed-in tariffs. This construction makes the fund largely independent of typical stock market fluctuations because its value does not depend on daily prices, but on the performance of the underlying tangible assets.²⁰

This is precisely where the benefit of an ELTIF addition lies. According to Dirk Holz, Chairman of the Management Board of Commerz Real Fund Management S.à r.l., such funds can be “both a source of return and an anchor of stability in volatile times”.

What do the track records of previous ELTIFs say?

There are only a few robust track records in the ELTIF market. At the end of 2025, 268 ELTIFs were authorised in Europe, of which 113 new issues were made in 2025 alone. Many of these funds simply do not yet have audited performance over several years. What providers communicate today in such cases is usually model forecasts, not returns achieved.¹

Sonja Knorr from Scope formulates a clear recommendation for the selection of suppliers: "Since you don't know in advance whether an ELTIF will be successful with its investments, investors should choose providers with a strong history. Such established companies have already proven that they can also be successful in difficult market phases."⁹

The ELTIF klimaVest is one of the few funds with documented multi-year performance. With a fund volume of around 1.6 billion euros, it is the largest ELTIF in Europe and has been on the market since November 2020. Since then, it has recorded positive performance in each financial year, most recently 3.7 percent in financial year 2023/24 and 3.5 percent in financial year 2024/25.²³

This continuity is not a coincidence, but is due to the tradition behind the house. klimaVest belongs to Commerz Real, a subsidiary of Commerzbank, which has been investing in tangible assets for over 54 years and also in renewable energies for more than 20 years.²⁴ This experience characterises the portfolio in several dimensions, from the weighting of the asset classes to the selection of technologies and the type of electricity marketing to geographical distribution across several European countries.

How to buy an ELTIF

Where can I buy ELTIFs, how does the subscription work? What costs do I have to expect? And are ELTIFs also available as savings plans? We deal with these questions in our own guide “Buying ELTIF”, including step-by-step instructions, cost comparison and overview of distribution channels.

To the guide: Buy ELTIF

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Chapter Seven: The role of ELTIFs in the custody account

Do ELTIFs offer inflation protection?

ELTIFs can offer protection against inflation, but the effect depends heavily on the asset class. It works most directly with infrastructure and renewable energies, where income is often secured through long-term, indexed electricity purchase agreements or regulated feed-in tariffs. If consumer prices rise, the revenue in many of these contracts also increases and the real value of the investment is retained.⁷

The other ELTIF classes have a more differentiated picture. Private debt ELTIFs often benefit from floating rate structures that increase their coupons during periods of rising interest rates. However, this is an interest rate effect, not a classic tangible value mechanism, and in an economic weakness phase, the default risk of the financed companies also increases.

For private equity ELTIFs, the protection depends on whether the financed companies can increase their prices with the inflation - i.e. not from the ELTIF envelope, but from the investments’ business model. In the case of real estate ELTIFs, protection is provided via indexed leases, similar to that of traditional open-ended real estate funds.

Anyone wishing to use an ELTIF as a targeted inflation protection should therefore pay attention to the fund’s cash flow logic.

How much should you invest in an ELTIF?

It is recommended to add between 5 and 10 percent of the assets to the custody account. The Consumer Centre mentions 5 percent as a sensible scale²¹, the upper threshold of 10 percent is also considered consensus value among advocates on the market.

Where investors end up within this range depends on their own profile. Those who already have a broad custody account of ETFs, shares and bonds, have a long investment horizon and experience with investments in tangible assets can approach the upper limit. Those who are just starting to set up a custody account or foreseeably need liquidity should be more cautious or initially invest in other building blocks.

It is helpful to think in euros instead of percentages. With 200,000 euros of liquid assets, 5 to 10 percent would be between 10,000 and 20,000 euros, an order of magnitude in which an ELTIF can really develop its diversification effect in the custody account.

What role does an ELTIF play in the portfolio?

It makes the most sense to consider an ELTIF as a tangible asset component and to use it accordingly - because it was created for precisely this potential. While equities are traded on the stock exchange and bonds provide the stability of fixed interest rates, the income of a conservatively constructed ELTIF comes from ongoing, often long-term contractually hedged cash flows, such as power purchase agreements, rents or regulated feed-in tariffs. According to Dirk Holz, Chairman of the Management Board of Commerz Real Fund Management S.à r.l., such ELTIFs can be “both a source of return and an anchor of stability in volatile times”.

However, in addition to this classic tangible asset role, the ELTIF spectrum has expanded significantly. As of the end of 2025, private debt is the most widely used ELTIF asset class with around one third of the market volume, followed by infrastructure and private equity.¹ This means that ELTIFs can also be used as a growth-oriented addition, for example via private equity in unlisted companies or via private debt with higher target returns. These strategies are suitable for experienced investors with a longer investment horizon and willingness to consciously add higher risks.

The role an ELTIF can play in the specific custody account therefore depends less on the envelope than on the selected asset class and strategy. "ELTIFs offer extensive investment opportunities, the keyboard is very extensive. This can help to diversify one’s own assets more widely," summarises scope analyst Sonja Knorr.⁹ The same term “ELTIF” stands for very different profiles, from a quiet tangible asset anchor to growth-oriented private market addition (or, in some cases, also daring speculation).

Who are ELTIFs suitable for?

An ELTIF is best suited to investors who plan long-term and consciously want to add a tangible asset component to their existing custody account. The typical investment horizon is at least five years, often significantly longer, and the amount invested is planned to be tied up for this period.

Specifically, an ELTIF fits well with a profile that meets four points:

Long investment horizon: an ELTIF derives its value over years from ongoing cash flows or the subsequent sale of investments, not from short-term market movements.
Already established custody account: liquid components such as ETFs, equities or bonds are available, the ELTIF is used as a supplement.
Liquid reserve outside the ELTI F: Sufficient funds in overnight or clearing accounts so that short-term cash needs do not lead to forced returns.
Experience with tangible asset investments: a certain understanding of the mechanics of long-term unlisted investments.

These prerequisites are not randomly selected. They reflect the long-term, illiquid nature of an ELTIF and are even set as prerequisites in the first generation of the Regulation. For ELTIFs under these original rules, which also include klimaVest, a minimum investment of EUR 10,000, an upstream suitability check at the distributor and a 10% ceiling for investors with securities assets below EUR 500,000 continue to apply. Anyone with the profile described above usually meets these requirements anyway.

For most retail investors, the focus is on tangible asset-oriented ELTIFs from the infrastructure and renewable energy sectors. Your income comes from current, often contractually hedged cash flows from power purchase agreements, feed-in tariffs or rents. They are suitable for investors who are looking for a quiet tangible asset alongside equities and bonds or want to give their capital a concrete contribution to the energy transition because it actually flows into the construction and operation of wind and solar farms or electricity grids.

Another profile is growth-oriented investors who want to enter private equity or private debt as a conscious addition, i.e. in unlisted companies or SME loans. The return opportunities are higher here, as is the default and valuation risk. These strategies are advisory-intensive and are more suitable for investors who are already familiar with private market investments.

Who is an ELTIF more unsuitable for?

An ELTIF is the wrong choice for investors who need to access money in the short term, do not have a liquid custody account or significant total assets, do not have any contact with tangible investments or generally do not tolerate fluctuations in value.

In practice, the following are the main situations in which an ELTIF is not suitable:

First-time investors without an established custody account: An ELTIF requires a liquid depository core with ETFs, equities or bonds. Those who have not yet built up a core should start there before adding private market investments.
Investors with low total assets: A minimum investment of 10,000 or 20,000 euros can quickly bind a third or more of the portfolio for small assets. This contradicts the function of an admixture module, which should not dominate the other depot components.
Investors without experience with tangible assets and private markets: ELTIFs work with mechanisms such as long holding periods, valuation prices instead of day prices and limited redemption windows. It is also complicated to understand the potential of individual plants such as wind farms or energy storage systems. Those who only get to know these concepts when studying the specific product have difficulty classifying opportunities and risks and should avoid getting started without advice.
Investors with foreseeable liquidity requirements: Anyone planning to make a larger purchase in the next few years, such as buying a house, renovating or financing the children’s studies, should not tie up the money provided for this purpose in an ELTIF.
Emergency funds, short-term reserves and basic retirement pension: Funds that are readily available or essential for securing livelihoods are not included in an ELTIF by design. Daily allowances, fixed-term deposits or traditional retirement products serve this purpose better.
Investors with low tolerance for fluctuations in value: Conservatively oriented ELTIFs are also subject to valuation changes. If you cannot live with fluctuations, interest-bearing products are the more suitable form of investment.

These restrictions do not speak against ELTIFs as an asset class, but against their use in the wrong context. Anyone who can exclude the aforementioned conditions and understands the mechanism of the product will find an investment form in the ELTIF market that makes sense to complement a classic securities account.

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Chapter eight: ELTIFs: Safety, Security & Sustainability

What legal protection do ELTIF investors have?

ELTIF investors are protected by five legal layers of protection:

Supervision. Each ELTIF is authorised by a national authority, in Germany BaFin, in Luxembourg CSSF, in France AMF. It is under constant supervision.
Regulated fund management. ELTIFs may only be launched by authorised capital management companies or alternative investment fund managers.
Depository. An independent depositary keeps the Fund assets separate from the assets of the Management Company and controls the use of funds.
Transparency before purchase. Retail investors will receive a key information document with risk and cost details as well as a prospectus. Regular reports will follow during the term.
Suitability test. A suitability check in accordance with the MiFID II standard is required for distribution to retail investors. The bank or adviser must clarify whether the product is suitable for the financial situation, experience and investment objectives.

This protection is organised at European and national level and covers supervision, management, custody and distribution. It does not include any guarantee of investment success.

With the ELTIF 2.0 reform, the previous barriers to access have been eliminated, i.e. the minimum investment of EUR 10,000 and the 10% asset limit below EUR 100,000 net assets. The material investor protection through supervision, custodian, transparency and suitability checks has remained unaffected.²⁵

The PRIIPs risk class, or SRI for short, shows how high the product-specific risk is. It ranges from 1 for very low risk to 7 for very high risk and is included in each ELTIF’s Key Information Document. Defensive infrastructure and renewable energy strategies tend to be ranked lower than private equity-heavy or mixed private market products. Since 1 July 2025, klimaVest has had a risk class 1 of 7.²⁶

Please note: Investor protection for ELTIFs is structural protection, not a promise of success. Losses up to total loss remain possible depending on the product.

Are ELTIFs special assets?

Yes, ELTIFs from German providers are generally special funds. The fund assets are legally separate from the assets of the capital management company and do not belong to the insolvency assets of the management company in the event of an emergency. If the Management Company becomes insolvent, an independent depositary will take over the winding-up of the Fund and the assets may be transferred to another Management Company. The legal basis for this is Sections 92, 99, 100 and 100b of the German Investment Code.

ELTIFs from other EU countries follow a similar logic, but in accordance with the respective national fund law. klimaVest is established as a Luxembourg mutual fund pursuant to Part II of the Luxembourg Law of 2010 and is supervised by the Commission de Surveillance du Secteur Financier (CSSF). Fund assets and management company are also legally separated here, an independent depositary controls the use of funds. The economic protective effect is therefore the same as for a German special fund, but the formal legal basis is Luxembourg fund law.²⁷

Important remarks: The special fund logic protects against the insolvency of the management company. It does not protect against economic losses of the ELTIF itself, i.e. against losses in the value of the holdings, credit defaults or a limited possibility of redemption in stressful periods.

What happens if an ELTIF fails economically?

The economic failure of an ELTIF looks different to the insolvency of an industrial company. It typically manifests itself in three stages for funds: depreciation, limited redemption and, in extreme cases, liquidation of the fund.

In the first stage, the investments or loan receivables in the portfolio lose value. This can be due to depreciation on individual investments, lack of cash flows from infrastructure projects or defaults on corporate loans. The net asset value falls and investors see book losses in their custody account view.

In the second stage, loss of value meets liquidity pressure. If many investors want to redeem at the same time and the fund holds illiquid assets, they cannot be sold in the short term without realising further losses. Semi-liquid ELTIFs can activate a so-called gate in this situation, i.e. temporarily limit or suspend redemptions in order to protect the Fund and the remaining investors.

At the end of 2025, an ELTIF from the German food retail real estate sector temporarily suspended returns after the requests for returns exceeded the contractual threshold in the third quarter.¹ Important: A gate is not an insolvency procedure. In this case, the Fund’s ongoing business operations and asset management continued.

In the third stage, a fund can be wound up in an orderly manner if the economic basis is permanently lost. The assets are then sold over a longer period of time and the proceeds flow back to investors on a pro rata basis. In this constellation, losses up to the total loss of the invested capital are possible, unlike for classic special funds, which are protected against the insolvency of the management company, not against economic losses of the fund itself.

For your own risk assessment, it is therefore important to differentiate between: The insolvency of the Management Company does not legally affect the Fund assets. Economic failure of the ELTIF very well affects the capital deployed. Both scenarios are part of the risk profile of this asset class.

How are ELTIFs classified under SFDR?

Under the EU’s Sustainable Finance Disclosure Regulation (SFDR), ELTIFs are classified in three transparency categories:

Article 6. Products without a designated sustainability objective. They only need to disclose whether and how sustainability risks are included in investment decisions.
Article 8. Products that promote environmental or social characteristics. Also called “light green” products.
Article 9. Products with a specific sustainable investment objective. Also called “dark green” products.

Important remarks: Articles 8 and 9 are not state labels but transparency categories. They oblige providers to disclose and make sustainability characteristics traceable. However, they do not guarantee that a fund will actually be as green as its label suggests.

In the current market, the “green” categories clearly predominate. Of the 113 ELTIFs newly launched in 2025, around half rely on an ESG or sustainability reference in accordance with Article 8 or Article 9 of the SFDR. Which asset class an ELTIF covers greatly influences the classification: Private debt and private equity ELTIFs are more commonly classified under Article 6 without an explicit sustainability reference, while infrastructure and renewable strategies are predominantly classified under Article 8 or Article 9.¹

It should be noted that the SFDR is currently being reformed. On 20 November 2025, the EU Commission presented a proposal to replace the current categories of Article 8 and Article 9 with three new ones: Sustainable, Transition and ESG Basics. Applicability is expected from 2028.²⁸

Thus, the SFDR classification is an initial filter, but not evidence of the actual sustainability of a fund. How resilient an Article 8 or Article 9 label is depends on the specific investment objective, the portfolio and the quality of the report.

As a proven example of an Article 9 product: klimaVest pursues the investment objective of making a positive, measurable contribution to the environmental objectives of the EU Taxonomy. Disclosure under Article 10 SFDR requires at least 80% of investments to be sustainable and pursue only environmental objectives.²⁹

Are ELTIFs sustainable?

ELTIFs are not sustainable as a class. Only individual ELTIFs whose investment objective, SFDR classification and actual portfolio also support this are sustainable. The ELTIF envelope itself is a regulatory vehicle, not a sustainability promise.

In the current market, the picture is divided into two parts. Approximately half of the ELTIFs newly launched in 2025 have an ESG reference in accordance with SFDR Article 8 or 9.¹ The other half either has no sustainability reference or is missing information about it. Even within the “green” categories, the actual sustainability can be stressed differently.

The analyst Morningstar points out in his report "The State of ELTIFs 2026" that the market boom makes conflicts of objectives visible. Liquidity reserves, leverage, high fees and valuation issues can overwrite the sustainable and stable narrative.¹¹ In other words: A “green” label does not automatically mean that every euro in the fund actually benefits the climate.

Those who specifically want to invest in sustainable ELTIFs should check four pieces of evidence:

Disclosure under Article 10 SFDR. This includes the specific investment objective and the proportion of assets that must be sustainable.
Periodic sustainability report. Shows what was actually implemented in the portfolio, not just what was announced.
EU Taxonomy Ratio. Indicates the proportion of the portfolio that meets the EU criteria for environmentally sustainable economic activity.
Exclusion criteria. Which sectors or technologies the fund explicitly excludes.

As an example: klimaVest is launched as an Article 9 product with a focus on renewable energies, electricity grids and storage. The Article 10 disclosure stipulates that at least 80% of investments must be sustainable and pursue only environmental objectives. Each investment undergoes impact and ESG due diligence as well as so-called DNSH checks, i.e. checks whether the investment does not significantly harm other environmental objectives. A supplementary self-commitment generally excludes investments in nuclear power and natural gas, with the strict exception of hydrogen-relevant gas networks.³⁰

What role does the EU Taxonomy play for ELTIFs?

The EU Taxonomy is a classification system of the European Union that defines which economic activities are considered environmentally sustainable. For ELTIFs, it becomes relevant whenever a product advertises with environmental objectives or characteristics, i.e. typically for ELTIFs under Article 8 or Article 9 of the SFDR. These must disclose the proportion of taxonomy-aligned investments in the portfolio. Non-environmentally related ELTIFs use a negative rate which clarifies that the underlying investments do not take into account the EU criteria for environmentally sustainable activities.

For investors, the taxonomy ratio is a more concrete test stone than general ESG language because it is based on an EU-wide uniform definition. It makes the ecological substance of a portfolio measurable and is basically comparable across several providers.

For example, klimaVest reports a taxonomy alignment rate of 92.91 percent for the 2024/2025 financial year. In previous years, the figures were 100 percent (2023/2024), 100 percent (2022/2023) and 55.6 percent (2021/2022). Among other things, the Provider justifies the change compared to previous years with an adjusted calculation since July 2025. The proportion of sustainable environmental investments that are not taxonomy-aligned is reported as 0 percent.³¹

For your own assessment, this means: The taxonomy ratio is included in the annual report or periodic SFDR disclosure of each environmentally related ELTIF. It is a robust indicator, but should be read in the context of multi-year comparisons with a view to explained methodological guidance.

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Chapter 9: ELTIFs: Market image & outlook

How big is the ELTIF market in 2026?

In 2025, the ELTIF market crossed the threshold from a niche product to an established investment form. At the end of 2025, 268 ELTIFs were registered in Europe, managed by 129 asset managers. The jointly managed assets amounted to around 34 billion euros, which is well over 55 percent above the previous year’s figure. In 2025 alone, 113 new ELTIFs were launched, almost twice as many as in 2024. The supply side has also broadened: 56 companies launched an ELTIF for the first time in 2025.¹
In terms of volume, the market is divided into three main areas: Private debt at 34 percent, infrastructure at 28 percent and private equity at 22 percent. In terms of the number of funds alone, private debt leads the way - of the 113 new issues in 2025, the majority came from this area.¹

The situation is different for the largest individual products on the market: The highest-volume ELTIFs are consistently infrastructure funds, supported by tangible assets such as solar and wind farms or electricity grids. In Germany, this concentration shapes the picture particularly clearly - around 60 percent of the local ELTIF volume is attributable to infrastructure, a multiple of the European average.¹

Market status at the end of 2025 at a glance:

268 ELTIFs, 129 asset managers
34 billion euros in assets under management
113 new editions 2025
Private debt 34%, infrastructure 28%, private equity 22%
4.4 billion euros in German investors, of which 36.8 percent in klimaVest

The reform is particularly evident in Germany. Investors from Germany held around 4.4 billion euros in ELTIFs at the end of 2025, up 57 percent compared to 2024. Germany is thus the second largest investor market in Europe after France and has overtaken Italy. The largest share is by some distance attributable to klimaVest, which combined around 36.8 percent of the German ELTIF volume at the end of 2025.¹

Who is the largest ELTIF?

In Germany, the supplier landscape is much more concentrated than at European level. At the end of 2025, Commerz Real’s ELTIF klimaVest was by far the largest product on the local market with around 36.8 percent of the German ELTIF volume.¹

Internationally, the 2025/2026 market will be dominated by large asset managers who transfer private market strategies to the EU-regulated vehicle (including Apollo, EQT, BlackRock, KKR, Goldman Sachs, Morgan Stanley, Schroders, Amundi and Blackstone).
On the sales side, classic banking sales remain the most important channel, supplemented by digital platforms such as Trade Republic (Apollo, EQT) and Scalable Capital (BlackRock).¹

A consolidated top list of the largest providers by managed assets does not publish scope as the market shifts rapidly.

Where will the ELTIF market develop by 2030?

Growth expectations for ELTIFs are high, but can only be reasonably described in scenarios. Based on a provider survey, Scope expects volume growth of 20 to 30 percent for 2026, i.e. a market of around 41 to 44 billion euros at the end of 2026. By the end of 2028, the ELTIF assets could more than double to EUR 70 to 80 billion according to the scope estimate (source: Scope ELTIF Study 2026, as at 26 March 2026; Handelsblatt, 13 April 2026).
For 2030, these estimates are less sharp, but the direction is consistent: a market that is evolving from a niche to an established segment within the European fund landscape.

There are three drivers behind these figures:

Pipeline of new products. For 2026 alone, the providers surveyed by Scope expect around 100 further new editions. The focus is on private equity, followed by infrastructure and private debt (source: Scope ELTIF Study 2026, as of 26 March 2026).
Broadening the investor base. The ELTIF 2.0 reform abolished minimum investment amounts and reduced distribution hurdles, allowing retail investors to enter via banks, independent asset managers and neobrokers.
Political embedding. In its Savings and Investments Union of 19 March 2025, the EU Commission described the ELTIF as a central vehicle for mobilising long-term private capital. At the same time, the Commission is working on follow-up packages on market integration and on a revision of the PEPP Regulation (source: European Commission, Communication on the Savings and Investment Union, 19.03.2025).

What role will the pension deposit play from 2027?

With the Bundestag resolution of 27 March 2026 on the reform of private pension schemes, ELTIFs are receiving a place in state-subsidised pension schemes in Germany for the first time. The law is expected to enter into force on 1 January 2027. The distinction in the law is important: Only classic UCITS funds are permitted in the simple standard custody account, ELTIFs are not envisaged there. Only in the extended pension account can investors also subscribe to ELTIFs and receive government grants for them. ³²

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¹Source: Scope ELTIF Study 2026, https://www.dasinvestment.com/eltif-markt-rekord-bei-neuauflagen-volumen-springt-auf-34-milliarden/

²Source: Börsen-Zeitung (March 2026), https://www.boersen-zeitung.de/banken-finanzen/neo-broker-treiben-deutschen-eltif-markt

³Source: European Commission, Communication on the Savings and Investment Union, March 19, 2025, https://commission.europa.eu/news-and-media/news/savings-and-investments-union-better-financial-opportunities-eu-citizens-and-businesses-2025-03-19_en

⁴Source: Regulation (EU) 2015/760, as amended by 2023/606, Article 13, Consolidated German version on EUR-Lex (as of January 10, 2024): https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=CELEX:02015R0760-20240110

⁵Source: Delegated Regulation (EU) 2024/2759, Articles 4–6; direct link to the German version on EUR-Lex: https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=CELEX:32024R2759

⁶Source: klimaVest, FAQ and Fact Sheet (as of July 1, 2025), https://klimavest.de/de/downloads/

⁷Source: “Luxembourg Asserts Itself as the Home of the ELTIF,” Börsen-Zeitung, November 8, 2025

⁸Source: KAGB §§ 261 et seq. on closed-end public AIFs, https://www.gesetze-im-internet.de/kagb/

⁹Source: Frankfurter Allgemeine Sonntagszeitung, 26.04.2026, Dennis Kremer (Print-Ausgabe)

¹⁰Source: BVI Yearbook 2025, as of June 30, 2025, https://www.bvi.de/fileadmin/user_upload/Bestellcenter/publikationen_pdf__downloads_/2025_06_BVI_8257_2025_Jahrbuch_2025.pdf

¹¹Source: Morningstar, The State of ELTIFs 2026, March 26, 2026, https://www.morningstar.com/en-gb/business/insights/research/european-long-term-investment-funds

¹²Source: Stiftung Warentest Finanzen, “Well-intentioned, but not good,” April 1, 2026, Renate Daum (print edition)

¹³Source: Stiftung Warentest Finanzen, March 18, 2026, https://www.test.de/Eltif-europaeische-Langfristfonds-ueberblick-6286734-0/

¹⁴Source: klimaVest Fact Sheet 03/2026, https://klimavest.de/de/downloads/

¹⁵Source: Delegated Regulation (EU) 2024/2759, Annex II, https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=CELEX:32024R2759

¹⁶Source: klimaVest Fact Sheet, as of July 1, 2025, https://klimavest.de/de/downloads/

¹⁷Source: extraETF, as of October 1, 2025, https://extraetf.com/de/wissen/eltif

¹⁸Source: Commerzbank Fund Profile: klimaVest (KLV100), https://www.commerzbank.de/wertpapier/de/research/fonds/fondsportraet/KLV100.html

¹⁹Source: klimaVest, Press Release: Annual Report and Dividend Distribution, December 16, 2025, https://klimavest.de/de/

²⁰ Source: klimaVest product page, as of July 1, 2025, https://klimavest.de/de/produkt/

²¹Source: Consumer Advice Center, as of October 31, 2025, https://www.verbraucherzentrale.de/wissen/geld-versicherungen/sparen-und-anlegen/eltifs-neue-anlageform-mit-tuecken-96375

²²Scope Fund Analysis, “Clear Rules Bring Long-Awaited Momentum – ELTIF Study 2025,” March 27, 2025, https://www.scopeexplorer.com/files/get/?name=news.ReportFile/bytes/filename/mimetype/Scope_ELTIF-Studie_2025.pdf

²³Source: klimaVest, Press Release on Annual Report and Distribution, December 16, 2025; Commerzbank Fund Profile for klimaVest (KLV100), as of March 31, 2026, https://www.commerzbank.de/wertpapier/de/research/fonds/fondsportraet/KLV100.html

²⁴Source: commerzreal.com, as of 2026, https://commerzreal.com/de/energie/klimavest/

²⁵Source: BaFin, https://www.bafin.de/SharedDocs/Veroeffentlichungen/DE/Fachartikel/2024/fa_bj_1305_ELTIF_Neue_Regeln.html

²⁶Source: klimaVest, Fact Sheet, https://klimavest.de/de/downloads/

²⁷Quelle: klimaVest, Basisinformationsblatt; klimaVest-Jahresbericht 2024/2025)., https://klimavest.de/de/downloads/

²⁸Source: European Commission, https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=COM%3A2025%3A841%3AFIN

²⁹Source: klimaVest, Disclosure pursuant to Article 10 of the SFDR, https://klimavest.de/de/downloads/

³⁰Source: klimaVest, Disclosure pursuant to Article 10 of the SFDR; klimaVest, Commitment to oppose nuclear power and natural gas., https://klimavest.de/de/downloads/

³¹Source: klimaVest, Annual Report 2024/2025, https://klimavest.de/de/downloads/se

³²Sources: German Bundestag, Resolution on the Reform of Tax-Advantaged Private Pension Plans, March 27, 2026, https://www.bundestag.de/dokumente/textarchiv/2026/kw13-de-altersvorsorge -1156798 Federal Government, Response to the parliamentary question “Pension Provision Possible Through Investment in Infrastructure,” Printed Paper 21/5554, April 29, 2026, https://dserver.bundestag.de/btd/21/055/2105554.pdf

ELTIF definition, functioning, marketThe reference work 2026

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Contents

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Chapter One: ELTIF fundamentals

What is an ELTIF?

How did the ELTIF come about?

Why do we need an ELTIF?

What are the objectives of the ELTIF?

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Chapter Two: Functionality and regulations

How does an ELTIF work?

How is the value of an ELTIF calculated?

Why is an ELTIF so highly regulated?

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ELTIF 1.0 and ELTIF 2.0 - both regulations coexist

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Why are so many ELTIFs authorised in Luxembourg?

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Chapter Three: Comparison of ELTIFs and other fund types

How is an ELTIF different from an UCITS?

How is an ELTIF different from an Alternative Investment Fund (AIF)?

How is an ELTIF different from a closed-end fund?

How is an ELTIF different from an ETF?

How is an ELTIF different from an open-ended real estate fund?

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Chapter Four: ELTIF Forms

What form of ELTIFs are there?

In which asset classes do ELTIFs invest?

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The four ELTIF asset classes with possible assets

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Where do ELTIFs invest?

What are the benefits of operating across Europe as an ELTIF?

What does ELTIF 2.0 mean?

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Chapter Five: Liquidity and return in ELTIFs

How liquid are ELTIFs?

What does semi-liquid ELTIF mean?

What are the deadlines for ELTIFs?

Are ELTIFs tradeable on a daily basis?

How does the redemption of ELTIF shares work?

What happens at the maturity of an ELTIF?

Is there a secondary market for ELTIFs?

What investment horizon should you bring with you for an ELTIF?

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Chapter six: Return and risk of ELTIFs

What return opportunities do ELTIFs offer?

How safe are ELTIFs?

What are the risks of ELTIFs?

Can ELTIFs make my portfolio more independent of the stock market?

What do the track records of previous ELTIFs say?

How to buy an ELTIF

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Chapter Seven: The role of ELTIFs in the custody account

Do ELTIFs offer inflation protection?

How much should you invest in an ELTIF?

What role does an ELTIF play in the portfolio?

Who are ELTIFs suitable for?

Who is an ELTIF more unsuitable for?

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Chapter eight: ELTIFs: Safety, Security & Sustainability

What legal protection do ELTIF investors have?

Are ELTIFs special assets?

What happens if an ELTIF fails economically?

How are ELTIFs classified under SFDR?

Are ELTIFs sustainable?

What role does the EU Taxonomy play for ELTIFs?

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Chapter 9: ELTIFs: Market image & outlook

How big is the ELTIF market in 2026?

Who is the largest ELTIF?

Where will the ELTIF market develop by 2030?

What role will the pension deposit play from 2027?

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ELTIF definition, functioning, marketThe reference work 2026

Contents

Chapter One: ELTIF fundamentals

What is an ELTIF?

How did the ELTIF come about?