Section E of the client documents, the Preis- und Leistungsverzeichnis. This is the contract. Where it says “up to”, that is a maximum Scalable may charge, not a price it does charge. It sets derivatives at up to €9.99 plus up to 0.99%, Category 2 orders at up to €1.99, and fund, bond and ELTIF surcharges at up to 5%. The English text of the same document is the legally binding one for clients resident outside Germany and Austria, and it is identical in substance at every figure.

A separate page the price list points to by name. It prices things below the ceiling, and each discount carries its own scope and its own expiry — or none at all. The Goldman Sachs bond discount and the BlackRock ELTIF discount carry none, and are stated to run until further notice. This page carries a noindex tag, which is why it rarely appears in search results and why most comparison sites have never read it.

The marketing surface. It shows the net result of the first two documents as of today, and it carries no contractual force of its own. It is also the fastest of the three to go stale in either direction — Scalable’s own trading pages have carried superseded figures for weeks at a time, and comparison sites copying them inherit the error.

A spread surcharge of 0.99% on FREE and 0.69% on PRIME+ applies on the executed volume, on top of whatever commission the venue produces. The fee page’s own footnote sets the scope broadly: all financial instruments that track the value of cryptocurrencies, including ETPs, ETCs and ETNs.

It applies to savings plan executions too, where the commission is zero. A €1,000 crypto-linked purchase costs €11.89 on FREE — €9.90 of surcharge plus €1.99 of commission — and €8.89 on PRIME+. The surcharge is between three and five times the commission at that order size, which inverts the usual intuition about which number to check first. It is also the one place on this platform where the plan tier still changes what a trade costs.

Real-time SEPA deposits carry 0.99% on FREE and 0.69% on PRIME+. The important detail is how the €5,000 figure works: the percentage applies to the first €5,000 of the deposit, and every further euro is free. It is a cap on the charge, not a threshold above which the deposit becomes free.

So a €2,000 Instant deposit on PRIME+ costs €13.80, and an €8,000 one costs €34.50 rather than nothing. Standard SEPA transfers and direct debits are free at any amount and usually settle in one business day.

There is a second layer worth knowing. The broker terms describe Instant as an overdraft mechanism: Scalable may accept and execute purchase orders against SEPA direct debits that have not yet reached their value date, and states plainly that the clearing account may be further overdrawn as a result. A debit balance runs into Scalable’s credit pricing, published as a variable borrowing rate of 4.49% p.a. on FREE and 3.49% on PRIME+, charged quarterly. The contract itself sets only the cadence and the variability, never the number.

Bonds are priced differently from shares in a way the fee page does not draw attention to. At Category 2 they are a firm €1.99 — bonds are the only instrument class the price list prices there without an “up to”.

On top of that sits a spread surcharge of up to 5%, on every leg including savings plan executions. The special conditions waive it for bonds from the PRIME Partner Goldman Sachs, with no expiry. Outside that issuer, the surcharge can dwarf the commission entirely — 5% of a €5,000 bond purchase is €250 against €1.99 of commission.

The price list sets derivatives at up to €9.99 per single order plus up to 0.99% spread surcharge. The special conditions cut that for PRIME-marked products from seven named issuers: BNP Paribas, Goldman Sachs, HSBC, Morgan Stanley, Société Générale, UniCredit and Vontobel. We do not publish the reduced figure here, because the venues it attaches to are not priced on the current fee schedule and we will not quote a price we cannot source to it. Outside that issuer list, the ceiling applies, and the gap against any advertised derivative price is roughly tenfold.

The derivatives discount also carries an anti-churn condition: unusually high turnover, meaning same-day round trips beyond what private asset management reasonably implies, sits outside it, and on repeated breach Scalable may bill at contract rates, refuse further orders or terminate the relationship.

ELTIFs add a surcharge of up to 2% of NAV per year on the recurring base fee, billed monthly pro rata, plus up to 5% per order or savings plan execution. PRIME-marked BlackRock ELTIFs are exempt from all of it, with no expiry.

Scalable may receive monetary and non-monetary inducements from third parties in the Broker, including transaction-, volume-, inflow- and holdings-dependent distribution and trail commissions. It may accept rebates on execution-venue transaction fees, but only where the venue’s public tariff allows it and only where they are used exclusively to reduce client fees. Amounts may be determined across the whole client base and cannot always be attributed to a single trade or a single client. You are told the actual amount once a year, and order-level information is shown in the client area.

The clause that deserves attention is the one where the client agrees that Scalable may keep them — expressly contracting out of the default rule that would otherwise require inducements received on your behalf to be handed over to you. That is the economics of a low-commission broker, stated in the contract you sign.

Scalable’s own conflicts disclosure also names its revenue interest from acting as a liquidity provider, a market maker, at execution venues and in fixed-price dealing. And its execution policy states, in the binding text, that its choice of execution venues allows it to reduce its own expenses — venue fees, clearing and settlement costs, third-party charges — in order to keep total cost low for the client. Those three facts belong together.

On payment for order flow specifically: the EU has banned the practice under MiFIR Article 39a, including in Germany. Scalable publishes no statement of its own about PFOF or the ban on any page we have read, and we are not going to attribute a position to it that it has not taken.

The cash account schedule carries four lines, and one of them is a Verwahrentgelt — a safekeeping charge on cash balances — with the rate deferred to Scalable’s website or apps rather than fixed in the contract. We could not locate a published rate, and no page states that it is currently nil. That is a gap in the disclosure rather than evidence of a zero, which is why you will not find a “no negative interest on cash” claim anywhere on this page.

The Total Expense Ratio of the fund is not a Scalable Capital fee — it is deducted from the fund’s net asset value by the issuer. iShares Core MSCI World (IWDA) carries a TER of 0.20%; Vanguard FTSE All-World (VWCE) 0.22%. For a savings plan investor paying €0.00 per execution, the TER is the dominant ongoing cost by a wide margin, and small differences compound over decades. See the UCITS vs US ETF total drag study for the full arithmetic.