ING and Bitcoin: About 50 cryptocurrencies ETNs in your portfolio and the impact of delivery stateme

You can buy Bitcoin at ING Bank, but not in coins

At ING Bank, you cannot directly buy Bitcoin as a "cryptocurrency". The final entry into its Direkt-Depot (direct-linked securities account) is the Cryptocurrency Note (Crypto ETN): an exchange-traded note that tracks the price of cryptocurrencies. The bank offers about 50 such products in the promotion, from five issuers, and you can choose between a one-time purchase or a fixed investment plan of as little as 1 euro per month. During this process, you don't need a digital wallet or manage private keys. You end up holding securities, not cryptocurrency. This difference is crucial because it determines whether you spend more or save more money over many years, in two ways: the continued cost of the product and whether a one-year tax-free holding period applies.

This article aims to clarify ING Bank's crypto investments: which products are tradable, what transaction costs are, who actually pays a zero-euro order fee, and what factors tax treatment actually depends on to equate to direct purchases of Bitcoin.

Can you buy Bitcoin at ING? You can buy encrypted ETN, but you cannot buy physical coins

ING lists cryptocurrencies as a separate product group among its securities products rather than operating as a cryptocurrency exchange. On its product page, the bank described the service as accessing Bitcoin and other cryptocurrencies through the existing Direkt-Depot, without the need for a wallet and private key. There is no need to open a cryptocurrency exchange account or a custody solution for this: these securities exist in the portfolio like stocks or ETFs, enjoy the same settlement process and the same tax statements.

However, banks do not provide purchase services for real coins. There is no cryptocurrency trading function, no ING wallet, and no way to send purchased bitcoins to your own address. If you wish to hold coins in person, you need to choose a cryptocurrency exchange or a broker that provides physical delivery; we provide an overview of authorized providers in Germany in a comparison of regulated cryptocurrency exchanges.

For many investors, this is the attraction: familiar portfolio, tax statements are issued by banks, and there is no need to worry about private key custody. But the price is the terms in the product documentation, and the actual cost is higher than what the order fee implies.

What is a crypto ETN: A bearer debt instrument, not a crypto asset

ETN (Exchange Traded Note) is a listed debt security. Legally, it is the issuer's promise to pay you the value of the underlying asset, not your share of the asset. VanEck's key information document for Bitcoin ETN contains the following sentence: "This product is a bearer debt security under German law." It is certified by global notes centrally held by Clearstream Banking Frankfurt.

This is a crucial difference from investment funds, although it is often ignored. An ETF (exchange-traded fund) is a separate asset pool: the investor's money is separated from the assets of the fund management company, and the money remains even if the provider goes bankrupt. ETN does not have such isolated asset pools. It is a claim on the company, and its value depends solely on the company and the collateral it provides. For common crypto-ETNs,"physical support" means that the issuer stores a corresponding amount of cryptocurrency at the custodian for each issued note.

How is the difference between this product type and certificates and directly held coins? We compared in detail in a separate article "Bitcoin Certificates, ETNs or Coins". If you want to clarify the overall product classification, please refer to "Buying Crypto ETFs in Germany".

About 50 crypto ETNs from five issuers: What can be traded in a portfolio

在其加密货币页面，银行列出了五家高级合作伙伴作为发行商：21Shares、Bitwise、VanEck、WisdomTree和iShares。促销优惠涵盖约50种加密ETN。这涵盖了主要的基础资产，尤其是比特币，以及以太坊（Ethereum）和Solana，并根据发行商的不同，还包括其他加密资产和捆绑多种硬币的指数产品。

哪种ETN对应哪种基础资产，需从ISIN代码和产品名称中读取，而不能仅凭发行商判断：每家提供商都运行着多种票据。例如，VanEck比特币ETN的ISIN代码为DE000A28M8D0，发行商为VanEck ETP AG，列支敦士登金融市场管理局（FMA）负责该产品的关键信息文件。因此，一种ETN在德国可交易且拥有德国ISIN代码，并不意味着发行商受到德国监管。

每种票据都通过参考价格追踪表现。对于VanEck产品，该价格由MarketVector Indexes GmbH计算，该公司隶属于发行商，根据数字资产最重要交易场所的价格按流动性加权得出。每个交易日都会确定产品价格。这意味着您投资组合中的报价跟随的是发行商集团内公司计算的指数，而非您可以自行购买的单一交易所价格。

进入投资组合的是带有印章的证券：由发行商发行的债务票据。空盘子象征着随之而来的缺失部分——即硬币本身。

零欧元订单费由发行商支付，而非银行

During the promotion, the order fee for purchasing crypto-ETN is zero euros, but product costs, bid-ask spreads and incentive fees are still required. The footnote here is the key point. The bank explained the promotion: reduced order fees will apply during the promotion period and the bank will receive compensation from the distribution partner (i.e. the issuer). This phenomenon is called "inducement".

The arithmetic behind it is simple. Issuers make money by deducting ongoing costs from the annual investment value, rather than through your individual order. The longer you hold the notes, the more they make. Covering a one-time order fee is an investment for the issuer in a position that yields a return every year. Therefore, purchases are only free at checkout, but not during the holding period.

ING also expressly reserves the right to terminate the promotion, change the terms, or postpone the announcement of the promotion at any time. Therefore, zero-euro orders are a revocable condition rather than a fixed feature of the portfolio. Anyone planning for the long term is advised to calculate the standard order fee in the price list and verify it in the portfolio before purchasing. The large differences in order fees and spreads among German providers can be seen in our comparison of cryptocurrency brokers.

1.00% operating cost: calculation results for key information files

VanEck's key information document for Bitcoin ETN states that management fees and other administrative or operating costs account for 1.00% of the investment value, based on actual cost estimates from the previous year. Transaction costs within the product are stated as 0.00%. Publishers do not charge admission or appearance fees, although sales agencies may charge their own fees.

The document uses an example of US$10,000: quitting after one year, the total cost is US$100; quitting after five years, the total cost is US$490. The annual cost impact in both scenarios was 1.0%. The issuer recommends a holding period of five years.

Converted to a smaller amount: Anyone who puts 1,000 euros into a product with 1.00% ongoing costs will have to pay about 10 euros in the first year, regardless of whether the price rises or falls. This fee does not arise when purchasing directly on the exchange; there, you only need to pay the transaction fee and spread at the time of purchase and sale, and there will be no other fees after that, but you are responsible for your own custody. Therefore, the calculation boils down to a critical point: the holding period threshold at which the continuous product fee exceeds the one-time transaction fee for direct purchases.

Crypto ETN fixed investment plan starting from 1 euro: Differences from ETF fixed investment plan

Crypto ETN can also be purchased through ING's fixed investment plan. In the discounted fixed investment plan, the bank will include the execution fee as zero euros, plus product costs, price differences and incentive fees, and set a minimum installment amount of 1 euro. This puts the crypto ETN fixed investment plan in the same range as ETFs, funds, stocks, ETC and certificate fixed investment plans.

Technically, it works the same way as any securities fixed investment plan: on execution day, banks purchase units for installments, including fractional units. The difference from the ETF fixed investment plan lies in the underlying product, not the mechanism. The ETF fixed investment plan purchases units in an isolated asset pool, while the crypto ETN fixed investment plan accumulates debt securities from a single issuer. Therefore, long-term fixed investment is also building a risk concentration for the issuer, and it will increase as each fixed investment increases.

The second point involves taxation and is often ignored: in a fixed investment plan, each installment has its own acquisition date. If your product is subject to a one-year holding period, each installment will be calculated separately. After one year of deposit, not all positions are tax-free. Only old installments exceeding twelve months are tax-free.

Taxation: Delivery request determines a one-year holding period

On the product page, ING lists tax treatment opportunities equivalent to direct investment in cryptocurrencies, adding that if the holding period exceeds one year, capital gains may be exempt from capital gains tax. This is the bank's position and accurately describes the favorable situation. But what the sentence does not explain is what this equal treatment depends on.

The key is whether, as the holder of the bill, you have the right to request the delivery of cryptocurrency. If there is such a right to request delivery, tax authorities will usually treat the sale as a disposal of the crypto asset itself, i.e. a private disposal transaction under Section 23 of the German Income Tax Act, subject to a one-year period and an exemption threshold within that period. If there is a lack of a delivery claim, or if the price of the bill is tracked through derivative synthesis, the instrument is considered a monetary claim: the proportional withholding tax under Article 20 of the Income Tax Law applies at this time, there is no holding period requirement, and even if it is sold ten years later, it will still be subject to tax.

It is here that viewing product documentation rather than advertising material becomes particularly important. VanEck's key information document states: "Under certain conditions, investors can request physical redemption directly from the issuer or, in limited circumstances, cash redemption." Physical redemption means delivery of coins. However, the same document also states that authorized participants have the right to purchase a basket of products with 50,000 notes from the manufacturer and return them. Specific conditions for redemption are stipulated in the final terms and not in the information document.

Our assessment: Equal tax treatment is an issue for individual products, not a category attribute. The evidence lies in the document itself, a combination of physical redemption "under certain conditions" and a basket size of 50,000 units authorized for participants. Therefore, people holding three-digit amounts of notes in their portfolios should review the claims actually granted to the individual by the final terms before purchasing and discuss the results with their tax advisers. On the other hand, for many years, tax authorities have in practice treated physical support products with delivery claims as direct investments; but this is not a substitute for binding rulings on specific instruments. How to cleanly record holding periods and acquisition dates across multiple portfolios, see our comparison of cryptocurrency tax instruments.

In addition, changes are coming: A draft bill from the German Federal Ministry of Finance will make future gains from crypto assets taxable as investment income, regardless of the holding period. A parliamentary paper from May 2026 has been submitted to the Bundestag. No decision has been made yet. For the current year, the one-year period remains unchanged, and it currently appears that the draft will only affect assets acquired after December 31, 2026.

Issuer Risk: Meaning and Limitations of Clearstream Global Notes

ING clearly points out issuer risk in its risk list: If the issuer goes bankrupt, ETN holders face the risk of up to complete loss. This sentence is not a mandatory cliché, it describes the legal core of the product.

Clearstream Banking Frankfurt's global notes ensure that securities can be kept and transferred. But it is not a guarantee of the value of the claim. In bankruptcy proceedings, what matters is the coins in custody and the legal structure for allocating them to note holders. "Physical support" means that the cryptocurrency is indeed stored; whether and how quickly you can access it during bankruptcy proceedings is determined by the terms of the issue and the laws of the place where the issuer is located.

Another right that appears in the same document is that the issuer can call the product before the expiration date, when the redemption amount may be lower than the amount expected to expire. VanEck Bitcoin ETN has an expiration date of December 31, 2039. Calling before then is possible and will trigger a sale, regardless of whether the time is right for you. Which documents should be reviewed before purchasing are explained in our article on the risks of crypto ETN publishers.

Risk Level 6 in Level 7 and Securities Knowledge on File

In the key information document, VanEck Bitcoin ETN is classified as Level 6 risk on Levels 1 to 7. Issuers do not provide capital guarantees and do not guarantee minimum returns, and investors may lose all or part of their investment. The risk indicator is based on the assumption of a five-year holding period; if sold early, the actual risk may vary significantly.

因此，ING在首次下单前设置了障碍：要交易这些产品，必须在投资组合中记录证券知识。银行指出，加密ETN主要适合能够评估机遇和风险的经验丰富的投资者。如果您未在投资组合中更新这些详细信息，订单将被拒绝，必须先添加知识。

银行的风险列表中还包含四项广告材料往往省略的内容：价格波动导致的高损失风险、监管不确定性（因为法律变化可能严重影响价格和税务）、加密市场易受操纵和欺诈的影响，以及流动性风险，即在公平市场价格下无法交易加密资产的危险。在这个资产类别中，完全损失是可能的。

在权衡投资组合与直接购买时，决定性因素较少是回报率，而是谁持有硬币以及最终适用哪种税务规则。

ETN、ETP还是ETF：为什么德国没有真正的比特币ETF

这三个缩写经常被混用，新闻报道也是如此。ETP是交易所交易产品的统称，涵盖ETF、ETC和ETN。ETF是具有隔离资产池的投资基金。ETC追踪大宗商品。ETN则是此处涉及的债务证券。ING在其页面上将加密ETN描述为追踪加密货币表现的交易所交易产品，也称为加密追踪器。

Under European law, funds are not allowed to put their assets in a single cryptocurrency because risk dispersion rules prohibit doing so. In Europe, this restriction is the reason for the entire ETN construction. This is why Germany does not have a Bitcoin ETF in the legal sense, even though the term is ubiquitous. What exists are ETNs and ETC based on crypto-assets. Spot products approved in the United States are called ETFs, but they are subject to different rules and are generally not tradeable in German portfolios.

This provides a clear rule of reading for your portfolio: When providers talk about crypto ETFs, it is worth checking the key information file to see which product type is named in it. If it says "bearer debt securities," then you are holding ETN, and the issuer risks and tax issues above apply.

Portfolio and Own Wallet: When it is more cost-effective to detour through securities accounts

ING's offer has a clear audience: investors who already run securities portfolios, who view crypto assets as a mixed component of their balance sheet and are unwilling to assume responsibility for the private key. For them, the barriers to entry caused by exchange accounts that require verification and withdrawal addresses are eliminated. Further advantages noted by banks include reduced third-party risk (because they do not rely on external crypto services) and low price spreads compared to direct investment.

There are three reasons against adopting the portfolio route, which cannot be compromised. Continuous product costs continue to occur every year, even in sideways markets. Issuer risk adds to price risk rather than replaces it. And coins don't leave the product: you can't spend them, you can't transfer them, you can't use them as collateral, or you can't transfer them into your own hardware wallet.

Anyone planning to own or move crypto assets themselves is paying through ETN for packaging they don't need. In this case, the direct way is to withdraw money to your own address through an authorized exchange and assume all the responsibilities arising therefrom.

ING and Bitcoin: The holding period remains open without delivery requests

About 50 crypto ETNs from five issuers, zero euro order fees during the promotion period and fixed investment plans starting from 1 euro make it easier to start investing in ING. But the two things that came into play over the years were somewhere else: the ongoing cost of 1% per year and the question of whether your notes grant delivery claims. Before sending your first order, please take three steps:

• Read the product documentation before purchasing. Get the ISIN code of the ticket you are interested in and check the declared product type, ongoing cost level, and term end time in the key information file. See our Cryptocurrency Broker Comparison for details on how to browse these files.
• Confirm the right to request delivery before relying on the one-year period. 向发行商索取您产品的最终条款，并由税务顾问确认您案例中的税务待遇。使用我们加密货币税务工具比较中的工具记录持有期和取得日期。
• 将投资组合路线与直接购买进行比较。 将持续产品费与您计划的持有期进行比较，并与我们受监管加密货币交易所比较中授权交易所的交易费和价差进行比较。如果您无论如何都要自己持有硬币，那么决定就在那里做出了。

（截至2026年10月10日。本文不构成投资建议。价格和费用结构会发生变化；购买前请与提供商核实条款。）