flatexDEGIRO SE (FTK) Earnings Call Transcript & Summary
October 22, 2025
Earnings Call Speaker Segments
Operator
operatorHello, and welcome to the flatexDEGIRO Q3 2025 Analyst Conference Call. [Operator Instructions] Now I will hand the conference over to Achim Schreck, Head of Investor Relations. Please go ahead.
Achim Schreck
executiveThank you, and good morning, everyone. Many thanks for dialing in, and a warm welcome to our analyst call relating to our Q3 2025 results, which we published yesterday evening post market close. My name is Achim Schreck, and I'm heading the Investor Relations team here at flatexDEGIRO. With me today are our CEO, Oliver Behrens; as well as our CFO, Dr. Benon Janos, who will lead us through today's presentation. We also have with us Dr. Thomas Lindner, our Global Head of Finance; as well as my IR colleague, Laura Hecker. As usual, we would like to provide a short run through the presentation before we open up for your questions. And without any further ado, I'm very pleased to hand over to you now, Oliver. Please go ahead. The floor is yours.
Oliver Behrens
executiveGood morning, everyone, and welcome to the analyst call for our Q3 and 9-month results. Benon will run you through the details of our performance in the third quarter in a moment. I would just like to highlight a few key points. Last week, we already preannounced our revenue and net income for the third quarter, combined with a substantial raise in our full year guidance. Growing commissions and a stable interest income have led to further growth of our top line. At the same time, we kept personnel expenses and marketing flat year-over-year and significantly reduced our administrative expenses. The combination of both, growing our top line while staying cost focused, enables us to further scale our operations and continue to increase our profitability. The clear reduction of our admin expenses over the last 12 months was important. We promised it exactly 1 year ago and when we published our numbers for Q3 2024, and we delivered. While there are always certain elements to improve, our cost base in general is clean and sustainable now. To meaningfully increase our profits, the focus thus is on further expanding our top line, building new products, rolling out new services and driving customer growth. Crypto trading and securities lending are the 2 new products we have already introduced over the last 12 months. Let me give you a brief overview of where we stand with each of them. With crypto trading, we went live in December 2024, limited to flatex in Germany at first. We further extended it to DEGIRO in Germany during the second quarter of 2025. However, we really only got started now in Q3 when we began with the international rollout. With product launches in Austria, the Netherlands, France and Spain, we today give approximately 2 million customers access to crypto trading. And shortly, Italy, Portugal, Greece and Ireland will follow. As you can see on the chart, this international rollout has been a step change when it comes to traded crypto volumes on our platform. More than 30,000 customers have traded crypto with us so far. Adoption rates are rising, and we have also seen a pretty strong start into the fourth quarter. However, the crypto market is impacted by significant volatility and external impulses. In addition, we have only started our offering. So take these steps with a grain of salt. Nevertheless, the direction of travel is very clear. When it comes to the monetization of our crypto businesses, the average ticket size in the first 9 months as well as in the third quarter has been around EUR 2,300. As you know, we are charging a low commission of 50 basis points in all countries, but the Netherlands, where it is 29 basis points. The blended rate for the first 9-month was 47 basis points at a rate that over time will most likely develop towards 40 basis points with a rising share of trades in the Netherlands. Benon will later on also detail how the crypto business has supported the growth of our average commission per trade in the third quarter. But before I hand over to Benon, let me briefly comment on 2 other strategic initiatives we have started now. On the product side, we have started our securities lending program in October in the Netherlands and Spain, our 2 largest DEGIRO markets. We are thus enabling our Dutch and Spanish customers to now earn additional passive income on parts of the EUR 20 billion of assets they hold on our platform. Of course, not all of these assets will be in constant demand for securities lending desks. We continue to expect that some 20% to 30% thereof are really relevant for lending purposes. As we only got started this month, I hope you understand that it is too early to give any indications on adoption, pricing and actual volumes. We will now focus on rolling out the product to more DEGIRO customers and markets and increasing marketing and customer communication to drive adoption. Last, but not least, our treasury enhancements. Our customers today entrust us with cash deposits totaling over EUR 5.6 billion. We used close to EUR 1.3 billion thereof to provide margin loans to our customers at an average margin interest rate in Q3 of around 5.9%. On the remaining, over EUR 4 billion, we have so far been rather passive. We are using a small part as collateral in our operating business in form of bonds, but we are keeping the vast majority of cash at the German Federal Bank with overnight availability. In order to monetize this asset better while staying very risk averse, we will implement a full treasury system in Q1 2026. We are progressing well here and we'll start with internal testing already at the final stage of Q4 this year. The new treasury system will allow us a more active steering with our investments and a broader variety of instruments. In anticipation of this new system, we have already initiated an increased focus on investment in high-quality investment-grade bonds, predominantly with a AAA rating and a focus on Germany. First improvements are already reflected in our interest income in Q3. To summarize, in a positive market environment, we continue to do our homework on cost reduction, product rollouts and internal process enhancements. We are well on track to achieving our financial goals and the implementation of our most important strategic milestones. All of this is, at least to some extent, already visible in our Q3 numbers, for which I'll now hand over to Benon to guide you through the details. Thank you, and over to you, Benon.
Benon Janos
executiveThank you very much, Oliver, and good morning to everyone from my side as well. I trust you have already seen our pre-release and the updated guidance we published last week. I'm very excited to now walk you through our financial performance for the third quarter and the first 9 months of the year and share a bit more details over the next minutes. Now let me quickly take a moment to remind everyone on our commercial performance in the third quarter, which we have already shared through our monthly KPIs. Gross customer additions amounted to approximately 100,000, an increase of 9% year-on-year. As we typically see, the first quarter tends to be the strongest in terms of customer additions due to seasonal patterns. This year, it stood out even more, thanks to elevated market volatility. This is also true for trading, as one can see on the right-hand side in regards to settled transactions. In the third quarter, we settled 17.7 million transactions for our customer base. This accounts for a strong 20% increase compared to last year, but naturally less than what we did in the first quarter. However, I believe what really stands out is the fact that we have actually been able to repeat the strong Q2 numbers on both KPIs, which at the time benefited from additional tailwinds from market turbulences around the so-called Liberation Day in early April. October also got off to a strong start, continuing the positive momentum we saw over the summer. We will publish our monthly statistics for October and November -- sorry, for October on November 5 and share more details then. Assets under custody reached a new all-time high, coming in just shy of EUR 92 billion. We crossed the EUR 90 billion mark for the first time. Year-on-year that translates to a strong 42% increase; and even quarter-on-quarter, we experienced growth of 10%. Splitting the assets under custody into securities and cash, you can see a relative uniform development. Securities under custody grew 42% year-on-year and 10% quarter-over-quarter to now EUR 86.3 billion. At the same time, cash under custody grew strongly by 49% year-on-year and also 9% quarter-on-quarter, respectively. To some extent, cash under custody benefits from overall asset growth with a relatively stable ratio of 6% of assets being held in cash. This also means that we have seen a pretty stable trend of growing cash per customer over the last quarter, rising from around EUR 1,250 on average at the end of September 2024 to now around EUR 1,650 on average. Our customers are simply becoming more wealthy. To put it differently, when we apply just the current ECB rate of 2% as our interest income on these cash holdings, we are talking about an interest-related average revenue per customer of EUR 33. At close to 3.5 million customers, this basically equates to approximately EUR 115 million annually of recurring revenues. The increasing cash level is fueled by strong net cash inflows onto our platform, which, as you can see here, has continued in the third quarter, albeit at a more normal rate after the exceptionally high inflows of Q1 and Q2. In total, we recorded net cash inflows of a record EUR 7.2 billion in the first 9 months of the year. This represents an increase of 44% on a year-over-year basis. Moreover, the net cash inflows we have seen in the first 9 months of 2025 are already exceeding the full year's 2024 level of EUR 6.6 billion. It is worth noting that in the "first 9 months of 2025" only around 85% of these net cash inflows were reinvested compared to historical average of approximately 95%. Now as usual, we portray our revenue split in the past quarter on Slide 13. In the third quarter, revenues grew with 18% year-on-year. Commission income especially increased strongly by 34% year-on-year, which is mostly attributable to a continuously growing customer base, an increase in trading activity and a higher commission per transaction. I'll turn to that in a second. Despite a significantly lower interest rate environment, interest income remained broadly stable. Interest income only declined by 5% year-on-year and just 2% sequentially. This was less than what we previously anticipated. Higher amounts of cash under custody and a growing average margin loan book compensated to a large extent for lower interest rate levels from the European Central Bank. Moreover, we also benefited from a more active treasury strategy. Oliver mentioned this in his opening remarks already. Let me add some more details and briefly walk you through our updated treasury strategy and how we are managing our customer cash under custody. We have now initiated more active treasury activities while still maintaining our risk-averse foundation. This means we are selectively deploying cash to more interest-bearing investments where appropriate. As shown on the slide, we currently manage around EUR 5.6 billion in customer cash under custody. Thereof, we use some part of funding for our margin loan business with the current margin loan book volume of EUR 1.2 billion. A quick reminder, margin loan rates were reduced by around 50 basis points as of the 1st of July 2025 with headline rates of around 5.5% to 5.75% currently. As Oliver mentioned earlier, the average margin interest rate in the third quarter amounted to around 5.9%. This is driven by product/mix, i.e., allocated versus unallocated margin loans as well as margin loans in different currencies, for example, U.S. dollars, which have higher average margin rates. Moreover, our bond investments are now close to EUR 800 million. As explained earlier, we have slowly started to deploy a more active treasury strategy. To enhance yields while staying conservative, we have increased our exposure to high-quality investment-grade bonds. The majority of these bonds are AAA rated. This approach allows us to improve returns while preserving flexibility and security. This is a strategy we believe is well suited to the current market environment. These investments have already contributed positively to our interest income line in the third quarter of 2025. Last, but not least, over EUR 3.5 billion of our cash under custody are still placed overnight with the Bundesbank where we receive the current market interest rates. Once we have fully established the new treasury system in 2026, this should provide some more opportunities going forward. Turning to the next slide at the monetization of our trades. You can see that we were able to generate an average commission of EUR 4.83 per transaction in the third quarter of 2025. This implies a 12% year-over-year increase from EUR 4.32 in the third quarter of 2024. For the last few quarters now, we have seen a heightened volume in U.S. trade from which we benefit additionally due to the FX conversion fee of 25 basis points. The uplift from higher U.S. volumes is around EUR 0.20 on the average commissions per trade. While U.S. volumes came back slightly in Q2, they have picked up again in the third quarter, even slightly surpassing the previous highs of Q4 of last year and Q1 of this year. Additionally, crypto trading contributed positively to commission per trade with a positive impact of EUR 0.04. This is up from EUR 0.02 in the previous quarter as we expanded crypto trading to more markets during Q3; and as Oliver has already shown in the beginning, trading volumes have significantly increased accordingly. Moving to Slide 16. We have portrayed our different cost items and their development over the past quarters. Let me dive a bit deeper into the different drivers for each cost item. We have demonstrated strong cost control and all cost items are coming in significantly lower compared to the previous quarter. One, personnel expenses. Personnel expenses on a year-on-year comparison stayed broadly stable with EUR 26.3 million in Q3 of 2025 compared to EUR 26.1 million in Q3 of 2024. Sequentially, personnel expenses declined by 15%, driven by a clear reduction of current personnel expenses as well as lower expenses for long-term variable compensation. Second, on marketing. Marketing expenses amounted to EUR 6 million in Q3, which is broadly in line to the EUR 6.2 million reported in Q3 of 2024. On a quarter-on-quarter comparison, marketing expenses declined by 14%. Marketing expenses are seasonally front-loaded with Q1 typically seeing the highest spend followed by much lower numbers in Q2 and Q3 before picking up a bit again in Q4. Our average customer acquisition costs in Q3 of 2025 amounted to EUR 60, down 10% year-on-year from EUR 67 in Q3 of 2024. And thirdly and lastly, other administrative expenses amounted to just EUR 10.9 million, decreasing strongly by 38% year-on-year and 15% quarter-on-quarter. This decline is primarily driven by lower legal and consulting expenses as well as a positive one-off reduction in bank-specific contributions of around EUR 2 million in Q3. As previously communicated, we remain well on track to achieve our full year target for administrative expenses, aiming at a level of around EUR 15 million for the full year. These EUR 10.9 million in Q3 also include one particular item. More than 4 years ago, back in 2021, we conducted a marketing campaign promoting 0-cost trading that the German regulator, BaFin, did not appreciate and is currently evaluating. This might also lead to a potential fine at some point in time. For this event, we have already built provisions in Q3 of 2025 of approximately EUR 0.5 million. Moving on to our profitability development on Slide 17. Given the high scalability of flatexDEGIRO's business model, we have seen a strong increase in net income, driven by higher revenues and lower costs. With revenues increasing 18% year-on-year and continued cost discipline, we have managed to achieve a strong increase in net income, which rose by 57% to EUR 39 million. Our net income margin improved by 7 percentage points, reaching 30% in Q3. Let's now have a quick look at how the quarterly performance adds to our results for the first 9 months of the year. Our revenue line increased by 16% year-over-year, while net income grew over proportionally by 41% year-on-year, given the scalability of our business, tight cost control. Things have progressed much better this year than initially anticipated. These strong results as well as the initial potential emerging from the ongoing international rollout of crypto trading and the launch of our securities lending program also contributed to the second upgrade of our revenue and net income guidance for fiscal year 2025, which we communicated on October 15 already. As you can see on Slide 21, revenue growth is now expected to come in between 10% and 15% versus 2024, which already was a record year for us. The revenue range we are aiming for is thus between EUR 530 million to EUR 550 million. This is a significant upgrade to the guidance we have first issued in February of 2025. On the bottom line, we have even more significantly upgraded our expectations for net income. We are now anticipating a net income between EUR 150 million and EUR 160 million, resulting in growth rates of 34% to 43% year-over-year. This compares to our previous range of plus 15% to plus 25% we gave out in July this year. Turning to absolute numbers. If we compare the midpoint of our upgraded guidance, this translates to an increase of around EUR 60 million on the revenue side and EUR 40 million on the net income side compared to the initial guidance we gave out with our strategy update in February of 2025. To achieve EUR 40 million of additional net income based on a revenue uplift of EUR 60 million once more shows the operating leverage we can achieve in scaling up our business. We remain confident in our ability to deliver on these targets as we move through the last month of 2025. October has obviously been off to a pretty good start. However, we are not applying a direct extrapolation of October's initial momentum across the remainder of the quarter. At the same time, when we gave the guidance last week, we have also been mindful of the fact that expenses for long-term variable compensation are likely to increase again in Q4 given the strong share price performance recently. The guidance also reflects an overall cautious valuation approach and some potential housekeeping items in the process of preparing our annual financial statements. So I would like to emphasize that these are realistic targets, and we are confident to achieve results within this new guidance range. With that, I would like to conclude our presentation. But before I hand back to Achim for the question-and-answer session, I would like to finish with one quick remark. FlatexDEGIRO is constantly evolving, not just in regards to our operational growth and the implementation of strategic measures. At the end of September, we have successfully relaunched our corporate website with the aim of delivering an improved user experience that enables faster and more intuitive access to content for our key stakeholders and most importantly, our analysts and investors. The Investor Relations section has been comprehensively revamped and now offers much clearer and much more direct access to quarterly reports, presentations, company compiled consensus data and KPIs. We hope you like the new website. If you have any feedback or suggestions for improvement, please don't hesitate to let us know in the Investor Relations department. Now Achim, over to you.
Achim Schreck
executiveThank you, Benon, and thank you, Oliver, also for your introductionary remarks. We are now very happy to take your questions on our Q3 financials.
Operator
operator[Operator Instructions] The first question comes from Andrew Lowe from Citi.
Andrew Lowe
analystI've got one on crypto and the commission per trade and then the second is on your securities lending business. On the first one, you reported EUR 270 million of crypto volume in Q3, 47 basis points of fees. That implies EUR 1.3 million of revenues, which is a EUR 0.07 contribution in the quarter. Can I -- just clarify that your EUR 0.04 figure that you mentioned, Benon, is a 9-month figure and do you agree with the EUR 0.07 in Q3 alone? And then what are your sort of expectation for Q4 and beyond? Is it reasonable to assume that we get to, say, EUR 1 billion of crypto trading volumes for 2025, which would imply a EUR 0.13 contribution in Q4? And then how do you expect the commission per trade to evolve when you exclude the crypto contribution? Does this increases -- trade size increases and clients get more wealthy, that would be really helpful? The second question, as I said, is on the securities lending. You're currently only able to offer this on your DEGIRO platform, which is 40% of your securities portfolio. Do you expect policy changes that may allow implementation in Germany and Austria? It seems to me that this is in clients' best interest. So I'd be interested if you've had any feedback from policymakers so far on this.
Benon Janos
executiveThank you very much. I will start with the crypto question. I will then hand over to Oliver for the securities lending question. At the same time, the team is computing the EUR 0.04/EUR 0.07 question. But on your other comments on the crypto side. So I made a comment a while back that it's very realistic to achieve EUR 1 billion in crypto trading this year. Given what we have seen in the third quarter and the backloaded third quarter, in addition to the launch of the upcoming crypto activities in other European countries, we certainly would think that the EUR 1 billion total volume traded stands and is a realistic option for this year. I will comment on this, of course, explicitly when we portray our full year numbers. And maybe now quickly to the sec lending question.
Oliver Behrens
executiveYes. Thank you, Andrew. It's a very interesting question. Obviously, Europe is not like the United States of America. It's -- sometimes I say a set of independent franchise takers under one currency. And that's why regulatory interpretation of what is allowed and what is beneficial for customers might differ from country to country. On this happy note, we are discussing with the regulators the different interpretation of MiFID regulation and the impact on securities lending and so on to get to a more common view, but unfortunately, we are not yet there. Nevertheless, there are enhancements in Germany. There was also a change in recent legislation, which makes it a little bit easier, but not at the same level of what is available in the Dutch market. So it is not a half empty glass or it's rather a half full glass. We think we can do more, but not overnight. We might go live with DEGIRO in Germany for sec lending next year. But that is a constant dialogue we're having. So we will keep you posted latest in the update coming for 2026 outlook, which will happen somewhere in February of '26. I think we will be clearer by then on the rollout of further markets, especially on the flatex side. We totally agree with you that this would be very beneficial for clients, as this is a setup of a very institutionalized product with an auction process for the assets, for the securities lending. And it is, from our perspective, very attractive to participate in this program, and it should be as easy as the clients approach it, but we are not yet there. So we keep you posted. Thanks for your question.
Benon Janos
executiveAnd to finish off, our first initial check indicates that we arrive at the EUR 0.04 commission increase per quarter. And I would suggest that the Investor Relations team, a.k.a. Achim Schreck, will reach out to you after today's call to clarify that.
Operator
operatorThe next question comes from Amit Jagadeesh from UBS AG.
Amit Jagadeesh
analystI just have a couple. So on marketing, could you share some color on how we should think about this next year, whether there will be or you're currently assuming some growth in marketing expenses, say, for example, to help with pushing the new product initiatives? And then I guess just a question on capital allocation. Could you share your latest thoughts here? Are you looking at any forms of capital return? Any plans for new buyback programs, things like that? And then lastly, could you expand on the special effects that led to the increased tax rate this quarter? Is this a one-off or -- yes.
Oliver Behrens
executiveOkay. Do you want to start with the tax rate or the other way around?
Benon Janos
executiveWe can start with the 2 financial questions, and then we can hand over to Oliver for the marketing question. So I'll start from the back. It is a one-off effect. It's related to business activities we have terminated almost 10 years ago. And it's a long-standing dispute on a tax situation we have with the local tax authorities in Germany, which amounts to approximately EUR 1.4 million. We have agreed to take a charge for that just in case we continue to find arguments in order not to have this tax levied on us, but to be prudent, we put it into this past quarter, and it's indeed a one-off effect. With respect to capital allocation, I will repeat what I have been saying constantly over the past couple of quarters. We plan to issue a statement on that when we publish our full year numbers. So today, we will not make a comment on that other than saying that we grew really strongly this year, and we have seen how positive a cash position is to simply fuel and finance the requirements for regulatory capital from existing funds. We mentioned before, we did not expect that much of balance sheet growth this year, and it's always good to have cash at hand for that. But more details on capital allocation most likely in February next year.
Oliver Behrens
executiveYes, I can only echo what Benon said. Maybe to add to that, as some of you probably know, payment for order flow will be banned in Germany from next year. That could have impact on some of our competitors' business models. And it's always good, as Benon said, to have some cash at hand if others might run into trouble that we can look out for opportunities. You also asked on marketing. I think what we can see in this year 2025 is that we are definitely back to business with new products, new launches and growth. Nevertheless, we put marketing expenses this year at a similar level of last year. But at the same time, we need to see on which areas we want to grow next year faster. We're preparing for some new marketing approach on our core markets. I would say, so far, so good. More to come towards the year-end, but I think we will definitely not reduce all marketing expenses, we will be slightly up for the next year. But we are going through our planning as we speak. We will discuss this with our committees, our Supervisory Board, our stakeholders. And once we are in sync, we will return to the market and give you guidance that would hopefully be helpful. In a growing business like ours, it would not be prudent to reduce marketing expenses because we believe the opportunities are there to make those investments in a successful way for our shareholders. Hopefully, that satisfies your question.
Operator
operatorThe next question comes from the line of Mengxian Sun from Deutsche Bank.
Mengxian Sun
analystSo 3 questions from my side. The first one is on the net interest income. Just trying to understand the NII dynamic here better. You said Q3 was helped by the higher yields from the bond investment. In the treasury book, what are actually the incremental NII from the treasury enhancements in Q3 in euro million amount? And I assume the rest is coming from the margin loan growth and the customer deposit growth. And the second question is on the other operating expense. Thank you very much for explaining us the details for Q3. But if I add the EUR 2 million banking levies on top, we are probably -- and if I keep the EUR 50 million guidance for the full year basis, we're probably still going to see another EUR 3 million increase in Q4. Any specific reason for that? And the last question is on the white label banking. I remember you were commenting on the 2 new potential partnership on the deposit-as-a-service side in last quarter. Could you please provide any update on these partnerships?
Benon Janos
executiveWould you like to start the white label banking?
Oliver Behrens
executiveYes. So on the white label banking, deposit-as-a-service is one part. I think there will be good news. We will go live around Christmas with one new partner. And so the -- there's one other bank that will basically raise deposits and they will go-live in December for family and friends and then live to the market in January. And we have built a good pipeline of those names. Thank you for really going into all these details. We expect hopefully another 2 new partners for 2026, but it's too early to tell. And with the other 2 questions, I would suggest I hand over to Benon on the interest side and so on. Thank you.
Benon Janos
executiveSo on the other operating expenses, the EUR 50 million is the number I had first mentioned pretty much a year ago on the call. So we simply stick to a clean headline number. Yes, there might be some room, but we still have 2 months to go, and there is no point in adjusting an expectation for our cost base. So let's see what the fourth quarter will bring. I think what's almost more important is that we have shown that we have successfully turned around the cost discipline. We are now on track for a clean number, which, depending on how the fourth quarter develops, we may even undershoot a little bit. So I'm glad that we are on the lower side of the EUR 50 million and not on the upper side. And on the net interest income line, we just started the activities of expanding our treasury activities. The vast majority of our investments are in AAA investment grade -- sorry, AAA rating category with also a strong skew to Germany. So the uplift you get on these is not gigantic. It's a modest benign uptick compared to what you would get if you simply park your money with the Bundesbank. And we will probably do a more proper review of that when we present the full year numbers. But as a very rough estimate, a couple of hundred thousands, give or take, something like that. It's not in the millions.
Oliver Behrens
executiveI think what is important to add to what Benon rightfully said is the interest curve was not an ordinary upward sloped curve for many, many years now. We had an inverted curve with the highest point almost at the short end of the curve. And given the fact that we have now a flattish curve or slightly upward sloping curve, it is more beneficial to use additional instruments, swaps, repos and other money market instruments, and that is mixed basically with short-term bonds. For that, we are introducing the treasury systems and it will enable us to better manage both sides of the balance sheet in terms of ALM matching. That would reduce the volatility of our earnings because when you look at it, the cash and interest from cash relative to the overall earnings momentum created some volatility on the quarterly earnings, higher volatility than the trading activity of our clients. And that is not something which is perfect and that's why we are introducing the treasury system out of various reasons. One of them is this what I just explained. Hopefully, that helps you. And of course, you can get an enhancement. I think we said it already in the 3-year planning at the beginning of this year that we expect somewhere between 15 and 20 basis points enhancements on the cash once the treasury system is fully rolled out, and we cannot invest every money because we need to stay liquid and flexible. And you also know that SEPA Instant Payment was introduced, and we need to still see what the patterns of the clients will have an impact on daily liquidity. But directionally, I think that is still intact what we mentioned in the guidance at the first quarter in February of '25 for the future once the system is fully up and running.
Operator
operatorThe next question comes from Zach Wurz from Autonomous Research.
Zach Wurz
analystI've got 3 of them. Firstly, the release said that the updated guidance does not assume that operational growth in the first weeks of October continue with the same intensity through the year-end. Can you just give a little more color around what your assumptions are here or help us frame the guidance a little better? The second is on crypto. How does uptake of the offering thus far compared to your expectations in terms of number of trades and average ticket size? Has uptake in any of these markets been particularly better or worse than you were expecting? And then the last one is on the transition to a European SE legal structure. Is that still expected to take place during the fourth quarter? And my understanding is that you should see some minor operational cost savings as a result of this move. What do you expect the nature and magnitude of those savings to be, please?
Benon Janos
executiveMaybe we'll start with the last question. So indeed, the transition from a German AG to an SE is still on track. We have received regulatory approval for the capital and the new legal entity. So we are in the final stages of sorting the time frame to execute that. And as of today, we expect that process to be done by year-end. In terms of cost savings, they are minor. We don't expect anything gigantic from this one. Any cost savings are probably more linked to what we have issued earlier in combining our stock-listed entity and our bank unit into one, which is something we are slowly but steadily preparing for as communicated already to the market. On the first question, on the guidance. Look, we are -- this is a quarterly call, and we took the freedom to take the knowledge of a pretty good start into October. And we thought it's okay to take what we have seen, but not to extrapolate on until the rest of the year. So the rest of this year is basically our normal planning that we had, which implies a modest growth compared to last year, but less than what we have seen in the first days of October until today. I think that's the most fair statement, I can say mathematically. And on the crypto trading side, Oliver, would you like to take over?
Oliver Behrens
executiveWell, I think it's like, like in most of the other trades as well. Germany has the slightly higher average trade size than the other countries. But it's also fair to say we have not fully rolled out to every country. So the numbers, especially for the 4 countries we rolled out in October or September, have another full year, so it's too early to tell whether these numbers are stable or not. We still see the uptake rates going up, which means we have not -- it's not in a BAU steady-state situation with crypto trading that I think we will have better statistics somewhere in the summer or so of next year when we have a more relevant time frame to look at.
Operator
operatorThe next questions come from Ian White from Autonomous Research.
Ian White
analystJust a few follow-ups from my side, please. First on the treasury investments. Can you just clarify, are you adding interest rate risk with the increased flexibility there? And could there be any impact on Pillar 2 capital requirements from that? And maybe just can you also just clarify how the -- sort of how you're thinking about the increased flexibility for product rollout on the liability side. Should we expect to see term deposit products, for example, in the near future now that you have this flexibility on the asset side? That's question one. Secondly, can you just clarify for us how much of your revenue margin is linked to the size of the actual trade? I have in mind, it's basically just FX and crypto. But are there other pricing structures where you basically earn higher RPC when the actual value traded tends to be larger? That's question 2. And just finally, can you say a little bit more about the scope of the BaFin investigation that you mentioned? I'm assuming this refers to the DEGIRO goes zero campaign back in 4Q '21. What's the kind of worst case, I suppose outcome there is what I'm thinking of? Can you just say a bit more about that, please?
Oliver Behrens
executiveYes. Maybe I start with the interest rate risk. So let's put this way, of course, we will add a little bit of interest rate risk, but it's so minor that is not really material. To give you an example, if we have every money on the overnight deposit with the Bundesbank, then of course, if we add for a small proportion, short-term bonds, it is an extended duration beyond the overnight risk. But at the same time, we are buying only bonds that we can put into repo. We are buying short-dated bonds, 3 months, 6 months. That gives us an enhancement at and over and above of the overnight rate with the Bundesbank. At the moment, still, the Bundesbank rate, the ECB overnight rate is 2%. And you find some bonds in a high-quality AAA-related area with, I think we have 90 whatever percent of the, what, EUR 700 million or so we have in bonds in Germany. And the maximum duration we bought for maybe EUR 100 million of that is 3 years. So you can see from that calculation, of course, the duration is longer than overnight, but it's probably on average, I don't know what, maybe 4 or 5 months. We haven't done the arithmetic to give you an example. So we expect, again, the pickup to be 15 to 25 basis points. And with the new system, we can engage better in additional money market instruments to diversify the risk with repos, reverse repos, securities lending and so on. That would give us a little bit more flexibility. But you can be assured we have a risk-averse approach for our clients' money not to have any hiccups here. In terms of -- hopefully, that answers first part of your question one. The question towards additional products is clearly, yes, we are looking at, and we said this already at the beginning of this year at further product enhancements. And we are currently, again, going through the planning. We believe for generations of European savers, deposits is an area which we might consider. But obviously, as we are going through the planning and we are discussing these topics with our Supervisory Board and stakeholders and have to prioritize what we can do on the platform and how we -- and how quickly this would be available, we will say more to these changes at the capital markets outlook in February and come back on the situation. And maybe if I may, I also say something on this BaFin situation. We are in -- first of all, it's a topic from the past. It's not an actual issue. It's a topic exactly, as you said, from 2021 when previous management was a little bit, let's say, maybe an ignorance in the discussions with the regulators. We have a very good relationship with the regulators. We have open dialogue, but we still have to deal with some issues from the past, and that is 2021 is almost 5 years ago. The impact, as Benon mentioned, has already been mostly provisioned. And if there is an additional payment once we are in agreement, it will probably be not able for you to see that. So the impact will be is already in the numbers, let's put it this way, okay?
Ian White
analystIan, I would like to finish off with your second question. This was the question relating to products where we actually benefit from the size of the trade. You mentioned in your calculation 2 examples. I think I would add a third one, which is exchange traded products without specifying the details because they are very individual, but those are also as a trade category where size matters.
Operator
operatorThe next questions comes from the line of Christoph Greulich from Berenberg.
Christoph Greulich
analystThree from my side, please. The first one would be another brief follow-up on the new treasury system. So if I look at your slide where you break down how the cash deposits are being used, it looks like about 20% of the cash, which is not used for the lending book is currently invested in bonds. But what is kind of the final target here in terms of the liquidity portfolio? How much of that would sit in bonds and how much would, yes, remain parked at the Bundesbank. That would be the first one. Then secondly, on the cost side, you mentioned that you've reached now a clean sustainable level. So I'm just wondering what type of normal cost inflation we should expect from here on in the OpEx line? And then lastly, a follow-up on your comments regarding the average commission per trade. So if I look at the year-over-year comparison in Q3, it looks like that the average number has gone up by EUR 0.50 in total. You mentioned about EUR 0.20, yes, was coming from the higher share of U.S. trades, EUR 0.04 on crypto. So it means that there is still half of that kind of uptick contributed by other factors. Is that mainly the mix shift between the flatex and the DEGIRO brands? Or what other factors should we take into consideration here?
Oliver Behrens
executiveOkay. Thanks, Christoph. Shall I start with the treasury system, maybe. I would say we have not fixed a clear mix of product. But one thing is clear, we need to stay very liquid for our clients' money movements and so on. At the same time, credit spreads are at all-time low. So we will remain flexible when it comes to instruments. But obviously, because the money is very sticky, we can add a little bit of duration, but it is important for us that the bonds are available for repo that we can always fulfill and stay liquid for any money movement that happens. We will tap slowly into new areas like, as I mentioned, swaps, repos and sec lending. And the expectation is to create this 15 to 25 basis points enhancement. I would -- a ballpark number is at the moment, we think about whatever, 20%, 25% in bonds at the moment. And when we look at additional instruments once the system is running, I would say it's a little bit too early to tell what we will exactly do in terms of asset allocation because we don't know what the spreads look like once the system is running. And if the spreads are not attractive or the yield curve will go inverted again, we will stay at the short end of the curve because it will be most beneficial.
Benon Janos
executiveMaybe on the 2 other questions, your last question on the commission rate. Really, it's simply the product mix that benefited quite a bit to the numbers. So we simply had more revenue-generating trades and high revenue-generating trades compared to other trades, and we mentioned a few minutes ago, sort of which trades those are in general. So it's been a positive trend for us. And on the cost side, we haven't finished the modeling for 2026. Oliver alluded already to the fact that we are preparing currently all the documents to get approvals from the committees and Supervisory Board and so on. But clearly, it's not going to be 60. We don't expect any big changes next year. We expect normal inflation patterns and whether it's going to be a number of slightly above or slightly below 50, we simply don't know yet.
Oliver Behrens
executiveBut it's very clear, we will stay disciplined on cost.
Operator
operatorThe next question comes from Andrew Lowe from Citi.
Andrew Lowe
analystI've got a quick follow-up. Could you possibly disclose the share of customers that placed at least one trade during Q3? I think the last time it was disclosed was Q1 when it was 33%. So if you're able to share what that figure is for Q2 and Q3, that would be really helpful.
Benon Janos
executiveSo yes, we are happy to disclose that. For Q3, it's 30%. And if we look at the second quarter, it's also 30%. So we qualitatively always tend to say that about 1/3 of our client base is active in a given quarter, but the Q2 and the Q3 numbers were 30%.
Andrew Lowe
analystCan I just ask a quick follow-up? So that seems to be slightly below the figures from Q4 last year and Q1. Is there sort of any particular reason for that? And is 30% the right number going forward?
Benon Janos
executiveLook, it's hard to comment. Increased market volatility tends to benefit trade from existing clients, particularly from clients who trade with us frequently. So you don't have an even distribution of client behavior when you look at cohorts. People who trade or clients who trade tend to trade more on average than the average client when market volatility picks up, and that might lead to some of those effects. But the effects are not in a range that where we start looking at them with any special care or caution.
Operator
operatorThere are no further questions at this time, so I hand the conference back to the speakers for any closing comments.
Achim Schreck
executiveThank you very much all for your participation today in our Q3 call. As already mentioned, obviously, if you have any further questions, any follow-ups, Laura and myself are more than happy to take your calls and e-mails individually now after the call. And again, thanks for the good questions today during the call. Thank you very much, and have a great day. Goodbye.
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