comdirect 加密货币：储蓄计划中提供29种免交易费证书，但无单一加密货币

comdirect 加密货币证书交易：成本、风险与操作指南

多年来，comdirect 允许投资者在不持有加密钱包的情况下对比特币和以太坊进行投机。然而，您获得的并非真实的加密货币代币：银行会将“加密货币证书”存入您的证券账户，这些属于追踪价格的债务工具。这种投资方式的费用取决于价目表中的一个关键数字：每笔订单最低收费 9.90 欧元。因此，一次性投资 100 欧元的投资者需支付相当于本金 9.90% 的手续费。相比之下，目前通过定期定额计划（Savings Plan）进行同等金额的投资则无需支付任何手续费。

我们于 2026 年 10 月 4 日评估了产品页面和服务价目表，并重新计算了从 50 欧元至 25,000 欧元不同投资规模的 costs。结果清晰地显示出两类投资者的差异。

comdirect 的加密货币交易本质：是证书而非代币

comdirect 是德国商业银行（Commerzbank AG）旗下的品牌。其产品页面中有一句解释整个构造的话：“您购买的不是‘真实’的加密货币，而是该加密货币的衍生品。”该证券的价格走势几乎与标的资产一对一同步，双向一致。

A cryptocurrency certificate, also commonly known as an exchange-traded product (ETP), is an exchange-listed bearer debt instrument: a loan is issued to the issuer, with the repayment amount linked to the price of the underlying asset. This is decisively different from investment funds. Comdirect itself clearly pointed out that when using ETP and certificates, there is "no protection against the issuer's bankruptcy risk." In contrast, ETFs have segregated assets that will not be affected even if the fund management company goes bankrupt.

In practice this means: These units are deposited in your comdirect securities account like stocks or fund shares. You don't need a wallet and you won't get a private key. If you want to keep your own Bitcoin, this is not the right choice. But if you want all your assets to be consolidated in one securities account and intend to forgo key management, then this is the right place for your needs.

29 cryptocurrency certificates from five major issuers: Our statistics

comdirect's regular quota plan promotion list lists participating securities by issuer. We conducted statistics on this. This analysis was independently performed by cryptoticker.io on October 4, 2026, based on the product page of cryptocurrency trading and verified 29 securities identification numbers.

The distribution of issuers is as follows: 21Shares provides 15 securities, Bitwise provides 5 securities, VanEck provides 5 securities, nxtAssets provides 3 securities, and Invesco provides 1 securities. Of the 29 certificates, 22 are for a single cryptocurrency, and the remaining 7 are for baskets or indices, such as "Krypto Basket 10" or "Krypto Mid-Cap Index."

A total of 12 cryptocurrencies are individually covered. Five of them are based on Bitcoin, four are based on Ethereum, two each are XRP, Cardano and Solana, and one each are Bitcoin Cash, Polkadot, Stellar, Polygon, Litecoin, TRON and Avalanche. What is missing from the list is eye-catching: there are no securities for Dogecoin, Monero, and there are no mainstream non-permanent or pledged tokens of the past two years. If you want to diversify your investment more widely, you need to move to an exchange with MiCA licenses or use a broker with a larger product library; specific providers and their products can be compared through our crypto brokers.

A note below the 21Shares Form deserves to be mentioned separately: the issuer is registered in Switzerland,"therefore, in the event of bankruptcy of the issuer, Swiss bankruptcy law applies." This affects more than half of the securities in the promotion.

Single purchase order fee: 4.90 euros plus 0.25%

For purchases on non-recurring quota plans, the normal service price list applies. The basic fee for executing transactions in Germany plus order commission is € 4.90 plus 0.25% of the order amount, with a minimum fee of € 9.90 (applicable to order amounts up to € 2,000) and a maximum fee of € 59.90. In addition, fees and third-party costs of relying on trading venues may also arise. Orders placed by phone are charged an additional € 14.90, and orders placed by fax or letter are also charged € 14.90. The 15% discount enjoyed by heavy traders clearly does not apply to the execution of regular quota plans.

Customers on new securities accounts can enjoy a waiver: in German trading venues and over-the-counter trading, the fee per trade order is reduced to 3.90 euros, and the discount period is limited to 12 months. A new customer is defined as a person who has not held a securities account with comdirect in the past six months. Once the twelve months expire, transaction fees will revert to € 9.90 per transaction.

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

For small investments, the minimum fee constitutes the entire price. We calculated typical order sizes based on the price list formula (excluding price differences and product costs) to show the pure ratio of the rate to the order amount.

One-time investment amount Order Fee Proportion of investment amount 50 euros 9.90 euros 19.80% 100 euros 9.90 euros 9.90% 250 euros 9.90 euros 3.96% 500 euros 9.90 euros 1.98% 1,000 euros 9.90 euros 0.99% 2,000 euros 9.90 euros 0.50% 5,000 euros 17.40 euros 0.35% 10,000 euros 29.90 euros 0.30% 25,000 euros EUR 59.90 0.24%

There are two thresholds in the table. When the order amount does not exceed 2,000 euros, you always pay 9.90 euros because the calculation of "4.90 euros plus 0.25%" is still below the minimum limit; at exactly 2,000 euros, the two are equal. On the upper limit end, the upper limit of 59.90 euros is triggered when the order amount reaches 22,000 euros. As a result, although investors who invest a large amount at a time have higher absolute expenses, the percentage expenses have steadily declined.

The intuitive conclusion drawn from this is that it is expensive to purchase small one-time cryptocurrency certificates at comdirect. Taking the entry of 100 euros as an example, before the price changes, the cost is close to one-tenth of the investment amount. On exchanges with MiCA licenses, transaction fees for the same amount are usually in the range of a few tenths of percent plus the price difference; which providers hold licenses in Germany and their charging standards can be referred to our overview of cryptocurrency exchanges.

Regular quota plan promotion until December 31, 2027: 1.5% fee waived

The calculation logic here is completely reversed. For the 29 securities on the promotion list, the per-trade order fee (1.5% of the order amount) in the regular quota plan will be waived until December 31, 2027. You can start investing from 1 euro per month and you can set up to ten securities at a time. Market-standard price spreads, inducement fees and product costs are not affected, as are telephone, fax and letter surcharges.

The specific data are as follows: Suppose you invest 50 euros per month for one year. Under normal circumstances, a fee of 1.5% of the annual total of 600 euros is payable, that is, an order fee of 9.00 euros, which is distributed among twelve executions. During the promotion period, the fee is 0.00 euros. For comparison, a one-time purchase of the same amount costs € 9.90. In this product segment, regular quota plans are not only a more convenient option, but also an absolutely cheaper option until the end of 2027.

However, this promotion comes with two restrictions. First of all, the promotion has a time limit, and comdirect clearly reserves the right to change, extend or terminate the promotion at any time. Second, it does not apply to all types of securities accounts: customer accounts cared for by financial service providers and Pure accounts are excluded. If a certificate withdraws from promotion, the security will revert to its regular terms.

Issuer risk of ETP: Debt instruments lacking bankruptcy protection

The product structure is what distinguishes cryptocurrency certificates from other securities account products that look like funds. As a bearer debt instrument, the security carries the risk of possible bankruptcy of the issuer. Comdirect points out this "issuer risk" in its own risk list and recommends readers check the relevant issuer's collateral details.

A common form of collateral is physical support. According to the instructions on the product page, the issuer will purchase the corresponding amount of the underlying cryptocurrency and deposit it into a cold wallet managed by a licensed independent trustee. Cold wallets refer to storage media that is not connected to a computer at all or only briefly connected. Whether individual securities are supported in this way is disclosed by the issuer in the product details; this is information you should read in the prospectus before purchasing, not the marketing copy.

See our "Overview of German Cryptocurrency ETFs" for the relationship between this product family and real funds and German exchange-traded cryptocurrency products. The short version is: The so-called cryptocurrency ETFs sold in Germany are legally mostly ETP or ETN, which is exactly the type of construct provided by comdirect.

Price differences and product costs: Items other than order fees

Order fees are only a visible part of cost, not the only part. In each of comdirect's terms and conditions statements on cryptocurrency trading, three other items are listed: market standard spread, inducement fee, and product cost. A spread is the difference between the bid price and the ask price and occurs at both the time of purchase and sale. The product cost is the issuer's ongoing management fee, which is deducted from the securities on a daily basis. For cryptocurrency ETPs on the market, the rate is usually much higher than that for equity ETFs.

For honest calculation, the rates in the above table are only the lower limit. This figure only illustrates the fees charged by banks to execute transactions and does not mention the ongoing cost of securities. These two values are located in different files: one in the bank's service price list and the other in the issuer's key information file. If you only look at the order fee, you are only comparing half of the bill.

Holding Period and Taxation: ETP in Securities Accounts and Tokens on Exchanges

In terms of taxation, certificates and tokens are two different things, and the classification depends on the specific design of the security. comdirect does not make a statement on tax on the product page, and we do not make unverifiable claims here. Therefore, you should clarify to the issuer and your tax adviser before purchasing: Is the security considered an investment product or a disposal of the underlying cryptocurrency? This determines whether the holding period plays a role.

The draft cryptocurrency tax report by the Federal Ministry of Finance on October 2, 2026 shows that the issue is currently in a dynamic state and is expected to be submitted to the Cabinet for review on October 14. As long as no decisions are made there, the status quo remains the same. This has no impact on the cost issue of this article, but it could change significantly on after-tax returns.

Cost comparison with new brokers and licensed exchanges

Comdirect plays a clear role in this product category. If you own a securities account with this bank, are accustomed to thinking with securities, and want to invest a small amount of money every month to purchase certificates, then the bank has an advantage: until the end of 2027, the execution fee for regular quota plans will be zero. If you want to make one-time purchases on an irregular basis and for small amounts, this offer is not suitable because the minimum fee of 9.90 euros will be swallowed up before the revenue is generated.

If you want real tokens with your own private key, comdirect does not provide such services and need to find an exchange with a MiCA license. If you need to use a hardware wallet, you need to do so no matter what. If you are primarily focused on ongoing costs, then you should compare the issuer's key information documents side by side with the bank's price list before deciding on a route.

comdirect's cryptocurrency investment strategy: What to do now

• Compare the above table based on your planned order size: If your single amount is less than 1,000 euros, the execution cost is at least 1%; In this case, a regular quota plan with an order fee of € 0.00 until the end of 2027 is a cheaper approach, and you can find suitable alternatives and their costs in our broker comparison.
• Review the issuer's key information documents: Understand ongoing product costs and collateral types. For the 15 securities of 21Shares, if Swiss law applies in the event of bankruptcy, this is stated on comdirect's product page. The legal classification of these securities is explained in our "Overview of German Cryptocurrency ETFs".
• Deliberately decided on how to hold: The certificate does not provide a private key; if you want a private key, the path is through a licensed exchange and then transferred to your own device, and our hardware wallet comparison shows the options.

Summary Points

The offer is not essentially a cryptocurrency transaction in the narrow sense, but a securities transaction based on the price of cryptocurrency. The 29 certificates from five major issuers individually cover 12 cryptocurrencies; Dogecoin and Monero are missing. Regular quota plans will be free of order fees until December 31, 2027, while one-time purchases will charge at least 9.90 euros, so the proportion will be 9.90% when investing 100 euros. In addition, no matter which method is used, the price difference and product cost will be borne. The main source for all offer details is comdirect's cryptocurrency trading page; fee information is based on the banking services price list as of June 2026.

(As of October 4, 2026. This article does not constitute investment advice. Price and fee structures are subject to change; please check terms with your provider before purchasing.)