How is financial advice regulated in Germany?
As of 2026, Germany regulates financial advice by product line under the Trade Regulation Act (GewO), with one registration per line: §34d for insurance, §34f for independent investment intermediation, §34h for fee-based investment advice, §34i for mortgages and §34c for other credit (reliability B). EU frameworks sit above: IDD, MiFID II, MCD, GDPR with the BDSG, DORA in application since 17 January 2025 and the AI Act in general application from 2 August 2026.
Updated . Figures keep their period, source and reliability grade.
Key figures
| Metric | Value | Period | Source | Grade |
|---|---|---|---|---|
| Insurance intermediary registrations (GewO §34d) | 178,810 registrations | Q3 2026, checked 27 August 2026 | DIHK Vermittlerregister statistics | A |
| Financial investment intermediary registrations (GewO §34f) | 41,388 registrations | Q3 2026, checked 27 August 2026 | DIHK Vermittlerregister statistics | A |
| Mortgage credit intermediary registrations (GewO §34i) | 58,014 registrations | Q3 2026, checked 27 August 2026 | DIHK Vermittlerregister statistics | A |
| Fee-based investment adviser registrations (GewO §34h) | 375 registrations | Q3 2026, checked 27 August 2026 | DIHK Vermittlerregister statistics | A |
| Commission-remunerated intermediaries | 97 percent of intermediaries | 2022 to 2025 | BaFin, GDV, EIOPA and pool disclosures | C |
| Fee-remunerated intermediaries | 3 percent of intermediaries | 2022 to 2025 | BaFin, GDV, EIOPA and pool disclosures | C |
| DORA in application | 17 January 2025 application date | 2026 | EU regulation, Germany Intelligence package watchlist | B |
| AI Act general application | 2 August 2026 application date | 2026 | EU regulation, Germany Intelligence package watchlist | B |
The answer
As of 2026, Germany regulates financial advice by product line under the Trade Regulation Act (Gewerbeordnung, GewO), with one registration per line (reliability B). Insurance intermediation falls under §34d and independent investment intermediation under §34f. Fee-based investment advice sits under §34h, mortgage intermediation under §34i and other credit under §34c. Bank advisers work under their institution's licence and do not appear in these registers.
Above the national paragraphs sit the EU frameworks. IDD covers insurance, MiFID II investments and MCD mortgages. GDPR with the BDSG governs data, and DORA covers digital resilience.
The numbers
Every figure behind this answer sits in the key figures table above, with its value, unit, period, source and reliability grade: A official statistics, B reconciled from published sources, C modelled estimate, D indicative.
How the number is built
Each GewO paragraph has its own register entry, maintained by the regional IHK and aggregated by DIHK. One person or firm can hold several. The four rows add to 278,587, and that gross figure is not a count of unique entities because of cross-licence overlap.
The framework dates come from the EU regulations and German transposition acts as of 2026. DORA has applied since 17 January 2025. The AI Act has general application from 2 August 2026, with high-risk obligations on a staged timeline. The German implementation of CCD2 applies from November 2026. FiDA, the open finance framework, is on the legislative watchlist without an effective date. The Retail Investment Strategy is being watched for formal publication and transposition.
What it means for distribution
Product-line regulation shapes the adviser population. An adviser who wants to cover insurance, investments and mortgages holds three registrations and three sets of obligations. That is one reason multi-product advisers gather in networks and pools, which carry part of the compliance load.
Remuneration is commission-based for 97 percent of intermediaries. Fee-based advice, at 375 §34h records and 3 percent of intermediaries, is legally available and commercially marginal.
For anyone embedding AI into advice, the AI Act now applies in general. DORA governs resilience of the tooling. IDD and MiFID II still define what the advice must document. Assurance of AI-generated advice is therefore a regulatory question, not only a quality one.
Go deeper
- How many financial advisers are there in Germany?: from register rows to active advisers.
- What is AI assurance for financial advice?: checking AI advice against a legislation matrix.
- Germany market intelligence: the regulation watchlist inside the package.
- AFA assurance capability: the assurance pass, currently a pilot.
Related questions
- Do bank advisers need a GewO registration?
- No. Bank advisers work under their institution's licence and do not appear in the intermediary registers. That is why adviser estimates add a separate bank layer.
- Which EU rules change in 2026?
- The AI Act has general application from 2 August 2026 with staged high-risk timing. The German implementation of CCD2 applies from November 2026. FiDA has no effective date yet, and the Retail Investment Strategy is on watch for transposition (reliability B).
- How common is fee-based advice?
- About 3 percent of intermediaries are fee-remunerated against 97 percent on commission (2022 to 2025, reliability C). Fee-based investment advisers number 375 §34h records in Q3 2026 (reliability A).
Methodology and limitations
Each GewO paragraph has its own register entry, maintained by the regional IHK and aggregated by DIHK, and one person or firm can hold several. The four rows add to 278,587, which is not a count of unique entities. Framework dates come from the EU regulations and German transposition acts as of 2026 and carry reliability B.
Primary sources
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