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Home»Regulation»German pension fund NAEV tests crypto allocation as doctors scheme expands digital asset strategy
Regulation

German pension fund NAEV tests crypto allocation as doctors scheme expands digital asset strategy

NBTCBy NBTC12/01/2026No Comments6 Mins Read
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After years of debate on digital assets, a leading german pension fund has quietly completed a multi-year test of cryptocurrencies within its broader portfolio.

  • Doctors scheme in North Rhine-Westphalia enters crypto market
  • Two-pronged strategy and test-phase performance
  • NAEV keeps satellite crypto allocation while limiting risk
  • International context and institutional crypto tests
  • German pension landscape: cautious stance on crypto
  • Regulation, Spezialfonds and packaged exposure

Doctors scheme in North Rhine-Westphalia enters crypto market

The pension fund for doctors in North Rhine-Westphalia, Nordrheinische Ärzteversorgung (NAEV), has made its first structured move into crypto after a two-year testing phase. The first-pillar institution, which manages retirement savings for medical professionals, treated the pilot as a tightly controlled experiment. However, the process has now led to a small but formal allocation to digital assets.

Over the test period, NAEV trialled two distinct strategies, each implemented via exchange-traded products (ETPs). The initial cap for the trial was set at a maximum of 0.1% of total assets, equivalent to around €17m. Following the completion of the tests, the overall allocation threshold has been lifted to no more than 0.5%, or €85m, IPE reported.

Chief investment officer Bernd Franken explained that the first strategy was a capital-weighted basket of the 10 largest cryptocurrencies by market size. Moreover, this approach gave NAEV broad, direct price exposure to the crypto market. The second strategy, in contrast, focused on a more diversified equity-style approach to the sector.

Two-pronged strategy and test-phase performance

According to Franken, the second strategy is structured as a niche equity fund investing approximately 80% in crypto and blockchain companies and up to 25% directly in cryptocurrencies. That said, both strategies were executed via listed instruments, rather than through direct token custody, to streamline governance and risk oversight.

The performance of these ETP-based strategies was monitored closely throughout the two-year period. Franken described the test window as one of “extreme” volatility, typical of the digital asset market. However, despite sharp swings, the resulting returns for the strategies ranged between 100% and 300%, underscoring both the upside potential and inherent risk of the asset class.

At the end of the testing period, NAEV decided to fully unwind the first strategy. Franken said the straightforward crypto basket resembled gold in that it was seen as pure price speculation, without an underlying cash flow or intrinsic value to justify price movements. Consequently, NAEV concluded that this segment did not fit its long-term liability-driven approach.

NAEV keeps satellite crypto allocation while limiting risk

Despite divesting from the broad crypto basket, NAEV chose to retain the second, equity-oriented strategy. The CIO argued that the strong performance track record in crypto and blockchain companies provides a more fundamental basis for continued price development over time. Moreover, exposure to listed corporates offers more familiar metrics for valuation and risk monitoring.

The volume invested under this strategy remains below 0.5% of the pension fund’s total assets, Franken noted. For NAEV, these crypto-linked holdings are clearly defined as satellite investments, rather than a core pillar of the overall portfolio. The doctors pension fund crypto exposure is therefore intentionally modest relative to traditional asset classes.

Franken stressed that NAEV does not see cryptocurrencies as a long-term store of value comparable to sovereign bonds or real estate. However, in a diversified framework, carefully sized exposures via regulated instruments may add incremental return potential. This reflects a broader trend among institutional investors experimenting with crypto-linked strategies under strict constraints.

International context and institutional crypto tests

Globally, policymakers are also adjusting frameworks for retirement savings. In August, the US administration issued an executive order that opened the door for 401(k) savings and other defined contribution (DC) retirement plans to allocate a portion of assets to digital investments. Moreover, this policy shift encouraged some schemes to conduct their own pilot programmes.

One such DC scheme, referenced by IPE, carried out an extensive programme of testing and due diligence before deciding on a strategic bitcoin allocation. According to Cartwright, one year after implementation the position had grown by 56%. That said, these cases remain exceptions, given ongoing concerns about volatility and regulatory clarity.

For many large institutions, including every german pension fund that is still assessing digital assets, the focus remains on the balance between innovation and prudence. Moreover, schemes must reconcile headline performance numbers with internal risk limits and governance frameworks before committing to scalable positions.

German pension landscape: cautious stance on crypto

Clemens Schuerhoff, managing director at consultancy Kommalpha, told IPE that German pension investors generally remain cautious on cryptocurrencies and bitcoin. In his view, the asset class is largely perceived as highly volatile, speculative, and lacking a consistent pattern of risk-adjusted returns. Consequently, most institutions have so far preferred to stay on the sidelines.

Schuerhoff added that risk management questions are central. Cryptoassets operate on decentralised blockchains that are not directly regulated in the same way as traditional markets. However, this raises issues around counterparty risk, infrastructure reliability and potential default events, especially when using intermediaries to gain exposure.

The integration of bitcoin or native tokens into existing risk models is also complex. There are operational hurdles related to the incorporation of granular risk reporting, scenario analysis and the calculation and visualisation of stresses. Moreover, legacy systems at pension institutions are often not designed to capture real-time data for 24/7 markets, increasing implementation challenges.

Regulation, Spezialfonds and packaged exposure

Within Germany, the Fund Location Act (Fondsstandortgesetz) allows Spezialfonds to invest up to 20% of their assets in cryptocurrency. This regulatory framework creates theoretical room for institutions to increase exposure. However, Schuerhoff noted that usage appears limited, with most investors favouring a conservative approach.

He said he would not rule out the possibility that some domestic pension schemes already have small positions in packaged products that reference bitcoin or broader crypto baskets. These would typically be implemented through issuers offering ETPs or ETFs linked to digital assets, instead of direct token holdings. Moreover, such structures can simplify custody, reporting and compliance compared with operating native wallets.

According to Schuerhoff, it remains unlikely that a german pension fund will hold bitcoin directly via a blockchain wallet using private and public keys. The operational, legal and security requirements for such arrangements are substantial. That said, incremental allocations through regulated market instruments may grow if volatility moderates and regulatory clarity improves over time.

NAEV’s measured crypto pilot underlines how institutional investors are experimenting with limited exposure while maintaining a conservative stance. For now, crypto remains a satellite allocation for doctors in North Rhine-Westphalia, but ongoing performance and regulation will determine whether similar schemes scale up their positions.

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