Exchange traded funds (ETFs)

Exchange traded funds (ETFs) are one of the fastest-growing asset class in the world with a compound annual growth rate of 17% over the last decade and 18.9% in the past five years. Since 2013, the number of ETFs as well as the number of ETF promoters globally has more doubled. And there is no end in sight. PwC surveys consistently find strong optimism about the continued growth and ever-greater opportunities for the global ETF market.

Europe is the second biggest regional market for ETFs with around 16% of global AuM in 2023.

Luxembourg is the second largest ETF domicile in Europe behind Ireland and continues to be an important market – particularly for certain strategies and in light of recent trends.

Key trends

Opportunities and challenges for our clients

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Different players have different priorities - and different questions to answer

Promoters, now more than ever, are under severe margin pressure due to the ever-intensifying downward spiral of TER – relief can only come from scalability, e.g. through new distribution channels or new markets, or ever-higher operational efficiency through technology. Actively managed ETFs, the growing importance of APAC and LATAM, as well as increasing "retailisation" of ETFs across Europe are very promising opportunities for fund houses to expand their product range and tap into new, previously unseized markets.

Traditional managers of actively managed mutual funds are threatened by the emergence of actively managed ETFs – products which are today mostly not yet at the same level in terms of active strategies, focusing rather on semi-active or enhanced indexing approaches, however, which will continue to evolve. There are indications, particularly in the U.S., that institutional investors are preparing to shift their focus away from traditional mutual funds and towards actively managed ETFs – primarily for the significant cost advantage an ETF offers over a mutual fund. The European ETF industry has always lagged behind the development in the U.S. for a number of years so mutual funds managers must start to prepare now for what is to come – and find a way to compete with actively managed ETFs, either by launching an ETF arm themselves or by refining their positioning and competitive advantage against this threat.

With the ever-increasing importance of ETFs and continuously significant inflows – often at the expense of traditional mutual funds – also asset service providers, particularly such without a dedicated offering for ETFs today – must be concerned with how they can benefit from this development. This can mean developing a dedicated service offering and required capabilities for the ETF industry or enhancing an existing offering, e.g. through enhancement of STP offering or better alignment with market makers/ authorised participants (e.g. on technological standards). 

Distributors are usually the first to be confronted with increasing client demand – both institutional and retail – and as such there is a great opportunity for them to benefit from the continuous expansion of ETFs, leveraging in particular the trends of actively managed ETFs, emerging ETF regions APAC and LATAM as well as the increasing “retailisation”. As already evidenced in some markets, distributors have the chance to develop innovative new models and offerings for their clients, often based on strategic partnerships with different promoters and/or trading venues. 

Our service offering - tailored to your requirements

  • ETF structuring
  • Regulatory licensing and incorporation
  • Pre-marketing notification and monitoring
  • Market intelligence
  • Distribution strategy
  • ETF registration
  • Listing strategy
  • ETF listing/ cross-listing
  • (Pre-)Marketing material compliance
  • Delegate due diligence & distribution oversight
  • Regulatory and investor reporting
  • Tax compliance/ tax reporting
  • Tax efficiency
  • Investor tax impact analyses and investor tax reporting
  • Ongoing maintenance:
    • Launch of new sub-funds and classes of shares
    • Amendments to existing constitutive documents
    • Corporate secretary
    • Fund on-site support
    • Restructuring solutions (merger, contribution in kind, liquidations, etc.)
    • Compliance review and awareness
    • Governance and processes
    • Assistance with meeting mandatory regulatory deadlines with regulators and stock exchanges
    • Advice on local documentation requirements and changes in listing forms
    • Supervision of publications linked to ETF and listing
    • Monitoring of necessary information and contracts between local agents, distributors and Authorised Participants
    • Systematic update on regulatory reporting and maintenance requirements of the host regulators and stock exchanges
    • Training of fund staff

  • In addition to the audit of financial statements, our assurance services include:
    • Reviewing engagements in the context of interim dividend, contribution in kind, merger, liquidations, review of interim financial information;
    • Assurance reports on controls at a service organisation (controls reports, SSAE 16 reports);
    • Agreed upon procedures reports.
  • For ETF investors: independent opinions and reports that provide assurance on the financial statements.
  • For ETF management: observations and recommendations on financial reporting, accounting, tax and internal control issues from our professionals, including industry best practices.

  • Market- and competitor analysis in light of emerging product, technology and distribution trends
  • Identification and assessment of strategic options
  • Operational/ regulatory feasibility study for development of new product-/ service offering (e.g. active ETFs, crypto ETFs)
  • Business case
  • Identification and assessment of options at service provider level
  • Identification and assessment of options for potential strategic partnerships (e.g. distribution)
  • Strategic review of ETF domicile options (pros and cons for different asset classes, fund structures, distribution strategies, etc.) 
  • Project support for development and roll-out of new offering

  • Market- and competitor analysis in light of emerging product, technology and distribution trends
  • Identification and assessment of strategic options – e.g. launch of an active ETF business vs. refining competitive advantage over (actively managed) ETFs
  • Identification and assessment of structure/ set-up options – e.g. ETF share class vs. standalone ETF
  • Operational feasibility study for development of ETF product-/ service offering 
  • Analysis of relevant regulatory considerations 
  • Business case
  • Identification and assessment of options at service provider level
  • Identification and assessment of options for potential strategic partnerships (e.g. distribution)
  • Strategic review of ETF domicile options (pros and cons for different asset classes, fund structures, distribution strategies, etc.) 
  • Project support for development and roll-out of new offering

  • Market- and competitor analysis in light of emerging product, technology and distribution trends
  • Identification and assessment of strategic options for development of new service offering/ solutions (e.g. ETF savings plans, model portfolios, commission-free trading) 
  • Operational/ regulatory feasibility study
  • Business case
  • Identification and assessment of options for potential strategic partnerships
  • Project support for development, operational implementation and roll-out of new offering

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Contact us

Marius Pfeiffer

Senior Manager, ETF Leader, PwC Luxembourg

Tel: +352 62133 52 47

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