White-label investment platform: what asset managers need

Short answer

A white-label investment platform is a subscription and administration platform that a service provider operates under the asset manager's brand. It combines onboarding with identification under §§ 10 and 12 of the Anti-Money Laundering Act (GwG), a subscription flow, payment processing, connection to an electronic securities register, an investor dashboard, reporting and distributions. The allocation of roles is decisive: Investment brokerage requires a licence (for example under § 15 WpIG or § 32 KWG, and for fund units and investment products also under § 34f of the Trade Regulation Act, GewO) or tied agent status (§ 3(2) WpIG, § 2(10) KWG). Crypto securities register management generally requires a licence under § 32(1) with § 1(1a) sentence 2 no. 8 of the Banking Act (KWG) or, for investment firms, under § 15 of the Investment Firm Act (WpIG).

At a glance

Natural persons are identified, among other methods, using a valid official photo ID or an electronic proof of identity (§ 12(1) GwG).
Appropriateness test before investment brokerage: obtain information on the client's knowledge and experience (§ 63(10) WpHG).
Crypto securities register management generally requires a licence (§ 32(1) with § 1(1a) sentence 2 no. 8 KWG); investment firms need a licence under § 15 WpIG.
Go-live of a white-label platform with heartstocks: 6 to 10 weeks, including training and API integration.

What is a white-label investment platform?

A white-label investment platform is a ready-made technical infrastructure that an asset manager uses under its own brand, its own domain and in its own design. Investors see the asset manager, not the technology partner. The asset manager thereby avoids building onboarding, subscription, payment processing and register connection in-house.

White-label does not mean that obligations disappear. Every role in the process needs a responsible party with the appropriate licence: the intermediary for investment brokerage, the register keeper for the crypto securities register, the custodian for the keys and the issuer for the prospectus or securities information sheet. The platform maps these roles technically. White-label assigns each obligation to the appropriate party.

What building blocks make up such a platform?

Onboarding and KYC: identification of the contracting party, clarification of the beneficial owner and PEP screening under § 10(1) GwG. Video identification must meet the requirements of BaFin Circular 3/2017 (GW).
Appropriateness test: before investment brokerage, the investment services firm obtains information on the client's knowledge and experience and warns if the product is not appropriate (§ 63(10) WpHG).
Subscription flow: product selection, provision of the subscription documents, subscription form, confirmation and record-keeping.
Payment processing: payment in euros via SEPA, matching to the subscription, refunds in case of oversubscription.
Register connection: transmission of subscription data to the register keeper, which enters the security for the investor and carries out transfers (§§ 8, 17, 18 eWpG). For crypto fund units, the register must be kept by the depositary or a licensed firm mandated by it (§ 3 KryptoFAV).
Investor dashboard: overview of holdings, documents, payments and issuer notices.
Reporting: analyses for the asset manager on subscriptions, volume and investor structure.
Distributions: calculation and payment of interest, dividends or redemptions to the holders entered in the register.

Under § 12(1) GwG, natural persons are identified, among other methods, using a valid official photo ID or an electronic proof of identity under § 18 of the Identity Card Act. Anti-money laundering duties apply to the obliged entities under § 2(1) GwG, such as credit and financial services institutions, investment firms and management companies. From 10 July 2027, the EU Anti-Money Laundering Regulation (AMLR, Regulation (EU) 2024/1624) will also apply directly.

Build or buy?

The make-or-buy decision depends less on the software than on the licences. An asset manager can develop the interface and dashboard itself. However, it can only take on register management, crypto custody and investment brokerage itself if it holds or applies for the relevant licence.

Building block	Build in-house	Buy (white-label)
Onboarding and KYC	Own processes under the GwG and Circular 3/2017 (GW), connection of an identification provider	Integrated flow with video identification
Subscription flow	High development and maintenance effort	Configurable per issue
Payment processing	Check whether money remittance applies (§ 1(1) sentence 2 no. 6 ZAG) or an exemption under § 2(1) ZAG applies	Integrated payment via SEPA in euros
Register management	Generally only with a licence under § 32(1) with § 1(1a) sentence 2 no. 8 KWG or § 15(1) WpIG	Connection to a licensed register keeper
Crypto custody	Only with a licence for qualified crypto custody (§ 32(1) with § 1(1a) sentence 2 no. 6 KWG) or as an investment firm under § 15(1) with § 2(4) no. 3 WpIG	Licensed crypto custodian
Investor dashboard and reporting	Feasible, but requires interfaces to register and payments	Included under your own brand
Time to go-live	18 to 24 months of in-house development (heartstocks estimate)	6 to 10 weeks with heartstocks, including training and API integration
Own IT	Blockchain node, smart contracts, operations	no blockchain node, no smart-contract development, no IT project on the client side

Who needs which licence?

Whether the platform operator itself needs a licence depends on the activities it performs. Brokering transactions for the purchase and sale of financial instruments is investment brokerage (§ 2(2) no. 3 WpIG). Investment brokerage requires a licence (for example under § 15 WpIG or § 32 KWG, and for fund units and investment products also under § 34f of the Trade Regulation Act, GewO) or tied agent status (§ 3(2) WpIG, § 2(10) KWG). A further route for platforms is authorisation as a crowdfunding service provider under Regulation (EU) 2020/1503.

Role	Activity	Licence or status
Issuer	Issues the security, responsible for the prospectus or securities information sheet	Duties under the Prospectus Regulation and § 4 WpPG; check own licensing requirements case by case
Intermediary	Investment brokerage or advice to investors	Licence, for example under § 15 WpIG or § 32 KWG, for fund units and investment products also under § 34f GewO, or tied agent (§ 3(2) WpIG, § 2(10) KWG)
Register keeper	Keeps the crypto securities register (§ 16 eWpG)	Generally § 32(1) with § 1(1a) sentence 2 no. 8 KWG, exceptions include § 32(1f) KWG; for investment firms § 15(1) with § 2(4) no. 4 WpIG; for crypto fund units the depositary or a licensed mandated firm (§ 3 KryptoFAV)
Crypto custodian	Safeguards private keys for crypto securities	§ 32(1) with § 1(1a) sentence 2 no. 6 KWG (qualified crypto custody) or § 15(1) with § 2(4) no. 3 WpIG
Payment service provider	Accepts funds for onward transfer	Licence under the Payment Services Supervision Act (ZAG) if money remittance applies (§ 1(1) sentence 2 no. 6 ZAG) and no exemption under § 2(1) ZAG applies
Technology partner	Provides software and operations	Depends on the activities performed, case by case

The duty to perform an appropriateness test under § 63(10) WpHG applies to investment services firms, including investment firms within the meaning of the WpIG (§ 2(10) WpHG). For a tied agent, its activity is attributed to the liable investment firm (§ 3(2) sentence 2 WpIG). § 63(11) WpHG provides for exceptions that must be checked case by case.

More at heartstocks: Tied agent explained

How long does the setup take and what should you prepare?

The timeframe depends on the number of building blocks, brand customisation and the completeness of documents. Delays typically result from incomplete documentation, BaFin processing times for prospectuses and KYC and AML checks. This checklist helps with preparation:

Define the product and type of security (bond, profit participation certificate, share or unit in a KAGB structure).
Determine the target group and minimum investment, and derive the prospectus or securities information sheet requirement.
Fill the roles: intermediary, register keeper, custodian, payment processing.
Select building blocks and clarify interfaces to existing systems (CRM, accounting).
Provide brand guidelines, domain, copy and mandatory legal information.
Define the distribution concept; with heartstocks, distribution is the issuer's responsibility.
Prepare investor communication on risks: issuer risk, total loss, limited tradability.

How heartstocks implements white-label platforms

The heartstocks white-label solution is a ready-made platform for digital investment processing under the client's brand and logo, with heartstocks running invisibly in the background. The platform consists of eight combinable building blocks: onboarding and KYC, vehicle structuring, subscription flow, register keeping via regulated partners, investor dashboard, reporting, distributions and, optionally, a secondary market. Onboarding, customising and go-live take 6 to 10 weeks, including training and API integration, instead of 18 to 24 months of in-house development.

The platform is multi-tenant: one code base, any number of platforms, each client with its own branding, its own investor base and its own data room. REST and GraphQL interfaces connect existing systems such as accounting, CRM, data room and BI. The client needs no blockchain node, no smart-contract development and no IT project of its own. Investors are onboarded digitally with video identification once and can then subscribe on all heartstocks platforms without repeating KYC; they pay in euros via SEPA and need neither a wallet nor crypto knowledge.

With heartstocks, the regulated roles are connected: heartstocks provides investment brokerage as a tied agent of CONCEDUS GmbH, the tokens are issued in the Nyala register and held in custody via Tangany. heartstocks carries the regulatory framework for platform and structuring. The investor's holding is entered in the eWpG register and visible in the investor dashboard.

The first production platform under a client brand went live in 2023. According to its own figures (as of 2026), heartstocks, active in the market since 2021, has supported more than 15 tokenisation projects and structured more than EUR 200 million in volume. Alongside the white-label platform, heartstocks offers the stakeholder models referrer, distribution partner and API integration.

The issuer manages distribution to investors. heartstocks supports placement and investor access with reporting and closing, and issuers see the pipeline and subscription status in real time. Banks, asset managers and distribution partners can be involved as referrers or distribution partners. This article provides general information and does not replace legal or investment advice.

More at heartstocks: White-label platform and live demo Referrer, distribution partner, API

Frequently asked questions

Does an asset manager need its own BaFin licence for a white-label platform?

It depends on the roles taken on. Investment brokerage requires a licence (for example under § 15 WpIG or § 32 KWG, and for fund units and investment products also under § 34f of the Trade Regulation Act, GewO) or tied agent status (§ 3(2) WpIG, § 2(10) KWG). Register management and crypto custody can be outsourced to licensed partners, so the asset manager does not need these licences itself.

Is video identification permitted for onboarding?

Yes. BaFin has set out the requirements for video identification procedures in Circular 3/2017 (GW). These include trained staff, an uninterrupted real-time connection with end-to-end encryption and identity documents with verifiable security features.

How long does it take to launch a white-label platform?

With heartstocks, onboarding, customising and go-live of a white-label platform take 6 to 10 weeks, including training and API integration.

Who is responsible for the appropriateness test?

The duty under § 63(10) WpHG lies with the investment services firm providing the investment brokerage. For a tied agent, this is the liable investment firm to which the activity is attributed. The platform implements the questionnaire technically in the subscription flow.