General ruling to restrict the marketing, distribution and sale of turbo certificates to retail investors
With its general ruling of 15 October 2025, BaFin imposed restrictions on the marketing, distribution and sale of turbo certificates. It sets out strict conditions for all sales activities relating to turbo certificates targeting retail investors.
Table of Contents
Turbo certificates: Leverage and knock-out threshold
Turbo certificates are characterised by two key features: the leverage, which enables investors to participate disproportionately in the price movements of the underlying asset, and the knock-out threshold (also referred to as a knock-out barrier). If the underlying asset reaches (or “hits”) this threshold, the certificate expires; the investor suffers an immediate total loss. The subsequent development of the underlying asset during the originally intended term is irrelevant.
Risk warning like on cigarette packets
All sales and marketing information must include the following risk warning, worded exactly as prescribed by BaFin:
On average, 7 out of 10 retail investors lose money
trading turbo certificates. Turbo certificates are high-
risk products and not suitable for long-term investment strategies.
BaFin gives precise instructions on how the risk warning must be displayed – or how it must be verbally communicated.
Turbo certificate diploma
Before purchasing turbo certificates, retail investors must first pass a knowledge test. The test comprises at least six multiple-choice questions specified by BaFin. The test is considered passed only if all the prescribed questions are answered correctly.
BaFin does not impose a maximum number of failed attempts.
A passed test is valid for a maximum of six months. After that, the retail investor must take and pass the test again before making any further purchases of turbo certificates.
No incentives
BaFin explicitly prohibits any form of incentive in connection with the purchase of turbo certificates. In particular, no volume-based discounts may be granted.
Entire distribution chain obligated – including finfluencers
The general ruling is addressed to intermediaries, issuers and providers of turbo certificates – in other words, all financial service providers involved in the value chain.
However, the group of obligated parties is actually much broader. Intermediaries, issuers and providers must ensure that all third parties acting on their behalf to promote turbo certificates also include the required risk warning. BaFin explicitly mentions finfluencers in this context (see here for the current regulatory debate on finfluencers).
Background: Little understanding and high losses
The BaFin’s approach is based on a comprehensive market study and MiFIR reporting data concerning turbo certificates. According to these, nearly three quarters of retail investors who traded turbo certificates over a five-year period incurred losses. Among highly active traders, up to 90% suffered overall losses. The average loss amounted to more than €6,000 per investor.
On average, over one fifth of retail investors bought turbo certificates without having sufficient knowledge or experience to understand and assess the associated risks. This reveals stark differences between financial service providers: while the proportion of retail investors with a “negative suitability test” was below 5% at some firms, at others it was nearly half of all turbo certificate purchasers.
Implementation deadline by mid-June 2026
The financial service providers concerned must adjust their sales activities to the new requirements by mid-June 2026 at the latest.
