Germany had 14.1 million people invested in shares, equity funds or ETFs in 2025. Only 63,000 people actively traded CFDs or FX in the 12 months to February 2025.
The comparison appears in a new FM Intelligence's analysis of Germany's retail brokerage market. The two figures cover different products and periods, so their 224-to-one relationship is a scale comparison rather than a penetration rate.
Germany's Investors Are Not Necessarily CFD Traders
Deutsches Aktieninstitut recorded 2 million more investors in 2025 than a year earlier. Of the total, 9.2 million held only funds or ETFs, 2 million held only shares and 2.9 million owned both.
The leveraged segment followed a different path. Finance Magnates previously reported that the number of active German CFD and FX traders remained 25% below its 2021 peak, despite rising 3% from the previous year.
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Still, the two groups are not completely separate. The research found that 72% of leveraged traders began with shares or ETFs, while 84% were open to buying additional products from their broker.
That behavior supports an investing-first route, with leverage introduced later to suitable clients. CMC Markets' addition of multi-currency stocks and ETFs in Germany is one example of brokers broadening beyond leveraged trading.
Free Trading Faces a Post-PFOF Test
Germany's temporary exemption from the European Union's payment-for-order-flow ban expired on June 30, 2026. PFOF allowed trading platforms to receive payments from execution venues for directing client orders to them.
The model helped firms such as Trade Republic and Scalable Capital subsidize low or zero trading commissions. Finance Magnates examined the potential pressure on their economics before the German exemption ended.
New entrants now need pricing that works without those payments. Subscriptions, interest on cash, securities lending and asset-based services are among the alternatives considered in the report.
A Local License Is Only One Route
A broker can initially serve Germany through an existing European Economic Area license, subject to passporting and local conduct requirements.
A German investment firm with its own BaFin authorization offers more local control but requires substantially more capital and staff.
The analysis estimates €4.1 million to €9.3 million in first-year funding for a fully licensed local operation. The range combines setup expenses, operating costs and regulatory capital, but excludes additional runway, acquisition costs and hedging collateral.
Some brokers have already changed their product mix instead of rebuilding around CFDs. Germany-based RoboMarkets added more than 1,400 Xetra-listed stocks and ETFs after withdrawing leveraged products from its European offering.
The full FM Intelligence analysis compares the available regulatory routes, operating-cost assumptions, hiring requirements and competitor positions. It also outlines the performance thresholds that could justify moving from a cross-border pilot to a locally licensed business.
