Europe’s largest economy has managed to turn the EU’s attempt to create a single capital market into something rather more German: the European regime exists, but the domestic legacy model refuses to die.
The European platforms are now dying with it. On 1 October 2026, Bergfürst began its departure as a going concern. Its shareholders resolved to dissolve the company and wind down the platform. New investments are no longer being accepted. Existing contracts remain in place. But the platform itself is being wound up.
Players come and go. That is normal in a mature market. Except that Bergfürst was one of the last recognisable German real-estate platforms operating under the European Crowdfunding Service Providers Regulation (ECSPR). Engel & Völkers Digital Invest entered insolvency proceedings. Zinsbaustein was folded into Wiwin. Wiwin subsequently returned its ECSPR authorisation and continued under the national regime.
This is not another round of consolidation. The German ECSPR market is being dismantled. And that should interest Brussels considerably more than it appears to.
The market Europe was supposed to create.
The ECSPR was supposed to solve a very European problem. Before it, crowdfunding operated through different national frameworks, with different rules for platforms, investors and issuers. The objective of Regulation (EU) 2020/1503 was to create a harmonised framework for business crowdfunding, allowing authorised platforms to operate across borders under common requirements for authorisation, supervision, disclosures and investor protection.
The economics should have been obvious. Germany is the EU’s largest economy, with a substantial retail savings pool, a huge SME sector and a sizeable real-estate market. If a European crowdfunding passport was going to demonstrate its usefulness anywhere, Germany should have been one of the places. Instead, Germany produced a rather different experiment. By design or by regulatory path dependency, it retained the structures around which its domestic crowdinvesting market had been built.
The German workaround.
For much of the previous decade, German crowdinvesting relied on the Nachrangdarlehen, the qualified subordinated loan. It gave developers and companies access to retail capital without necessarily requiring a conventional securities prospectus.
It also created an extraordinarily convenient illusion. The investor saw an online platform, a project, an interest rate and a repayment date. The capital stack saw something else. Senior creditors sat ahead of the crowd. The crowd was subordinated. The banks loved this model. The European framework arrived after this model had become deeply embedded. Germany ended up with two worlds: the European crowdfunding regime and investment structures that could continue under national law.
This distinction is important. The ECSPR does not cover every online investment offer or every subordinated loan. The German Vermögensanlagengesetz explicitly includes subordinated loans within its definition of Vermögensanlagen. Depending on the instrument and the activities performed, national rules, prospectus exemptions or other financial-services legislation may apply. MiFID II is relevant where the instrument and services fall within its scope; it is not a blanket alternative regime for all crowdinvesting.
This is not a new regulatory tension. EUROCROWD has already examined how the coexistence of ECSPR and the VermAnlG creates parallel routes to market, with different regulatory treatment potentially applying to offers with comparable economic characteristics in a previous comment: A question of regulatory consistency.
The issue is therefore not that every national-law offer should have required an ECSPR licence. It is that economically similar investments can reach retail investors through different regulatory routes, with different obligations and costs.
Germany retained a national structure in which the domestic industry had already invested heavily. The result is a question of competitive neutrality that European policymakers should take seriously.
A shrinking domestic market.
A ECSPR register snapshot of ESMA of 6 October 2026 identifies two German providers authorised under ECSPR, one of them still Bergfürst. Three others were delisted officially in January 2026. The market developments tell their own story.
EV Digital Invest entered insolvency proceedings. Zinsbaustein was absorbed into Wiwin. Wiwin returned its ECSPR authorisation. Parts of EV Digital Invest’s servicing operations were taken over through a structure involving Bergfürst and Exporo. Now Bergfürst itself is being wound up.
Nor is the incumbent model a safe harbour: for example, in July 2026, OneCrowd, the group behind Seedmatch, Econeers and Mezzany, filed for insolvency proceedings for three of its companies, despite operating outside the ECSPR platform model. The failures in the German market are not confined to one regulatory route; they raise the more fundamental question of whether confidence in “German crowdinvesting” has been damaged across the market.
Investmentcheck‘s reporting on Bergfürst provides a glimpse of the economics. Its accumulated balance-sheet loss increased to €2.12 million in 2024, while equity fell to €4.22 million. The company’s reported €6.8 million damages claim was subsequently withdrawn, so it should not be confused with an outstanding liability. The figures nevertheless illustrate the financial pressures around a relatively small platform business.
Bergfürst is the latest chapter in a wider process of consolidation, licence returns and retreat from the original promise of a European crowdfunding market. EUROCROWD has tracked this shift across the ECSPR landscape in ECSPR at a turning point.
Bergfürst had tried to broaden its business beyond property, including through a gold offering. It did not save the platform. The obvious caveat is that property-market conditions, the quality of individual projects, funding costs and platform economics all matter. Yet, these closures do not prove that ECSPR caused the failures.
Nope, this is not an ECSPR failure.
ESMA’s 2025 market report recorded €4.25 billion raised by 181 authorised crowdfunding service providers across 21 Member States in 2024. Retail investors accounted for 88% of the investor base. France raised approximately €1.45 billion and the Netherlands €1 billion, with Spain, Italy and Lithuania also among the leading markets, according to ESMA, Market Report: Crowdfunding in the EU 2025.
The European market exists. It is not a Brussels regulatory fantasy. Germany is conspicuously absent from the leading group. Its domestic ECSPR ecosystem has contracted, even as European platforms can continue to serve German projects and investors under the passport.
The argument that ECSPR is simply too strict or too costly therefore misses part of the picture. The relevant measure of integration is not simply how many licences have been issued, but whether the harmonised framework becomes the effective route to market, or substantial activity continues through national structures. That is the broader question behind an earlier analysis of ours in Europe’s missing middle.
A harmonised platform has to build the compliance, governance, risk-management and disclosure infrastructure required by the European regime. A competing business operating outside that regime may face a different set of obligations. That difference may be justified where the activities or instruments genuinely differ. But where the economic substance is comparable, the competitive effects deserve scrutiny.
So, what happens when the harmonised regime is more expensive to operate than the national structures it was intended to supersede? Germany is an instructive case study. The question is not whether national regulation should disappear altogether. It is whether the coexistence of the two frameworks has entrenched a legacy model at the expense of the European one.
The cross-border irony.
German entrepreneurs and investors have not suddenly stopped wanting alternative finance. Non-German ECSPR platforms offer investments across borders, subject to the regulation and applicable requirements. German projects actively appear on platforms authorised elsewhere in the EU. This is what the passport was designed to make possible.
The irony is that cross-border provision under ECSPR seems to be working, though not yet in scale, while the domestic provider ecosystem contracts. If German-origin projects can be financed through platforms based in other Member States while domestic ECSPR platforms disappear, the question is no longer simply whether demand exists. It is where that demand can be intermediated economically.
That may be a success for European market integration. It is also an uncomfortable outcome for Germany, which has managed to retain a substantial legacy structure without building a comparably strong domestic ECSPR market.
And then there is the industry itself.
The market organised itself in a national trade association, Digital Invest Germany/Bundesverband Crowdfunding. The association positions itself as a representative of digital investment platforms in Germany and has been actively working with German policymakers and beyond to support the sector. Yet its public membership directory still includes Bergfürst, Engel & Völkers Digital Invest and Zinsbaustein. Other entries point towards additional inactive platforms, outdated websites or businesses that no longer appear to offer crowdfunding or digital investment in the familiar sense.
An association cannot be blamed every time a member closes down. Nor does an outdated directory, by itself, indicate much. But a trade association in a rapidly restructuring market should be more than a membership list. It should help explain what happened, what the legacy model got wrong, what investor-protection lessons have emerged and how the industry intends to adapt to the European framework. The risks are not merely theoretical: subordinated lending, insolvency recoveries and the communication of investment risk have been recurring concerns. We have examined that legacy previously in Germany’s crowdfunding hangover.
The sector itself offers no substantive explanation of the decline of the domestic ECSPR market or of the competitive tension between the two regulatory routes. And this is not about individual platforms, executives or lawyers. They all operated within the legal and commercial architecture available to them. Investors responded to yields and accessible online offers. Policymakers allowed national and European structures to coexist.
An industry that spent a decade optimising its products, distribution and legal structures around one regulatory model will not automatically change because a new European regime arrives. For retail investors, the coexistence can also be confusing. An online investment may look much the same on the surface while its legal instrument, regulatory protections and position in an insolvency differ substantially. The much needed explanations and public discussions are, however, missing.
A funeral, perhaps. But not for crowdfunding.
The German crowdfunding market is not disappearing because nobody wants alternative finance. It is contracting because a domestic industry built around a particular product and regulatory model has struggled or avoided to adapt to a European framework. The old model has the advantage of incumbency. The new model has the advantage of harmonisation. Arguably, neither has yet produced a compelling domestic business case at sustained scale.
Now Bergfürst is leaving the stage. EV Digital Invest is in insolvency. Zinsbaustein has been absorbed. Wiwin has returned its ECSPR authorisation. Exporo remains alone. The German ECSPR cohort, with only one platform remaining at this time, is a shadow of what a market of Germany’s size might reasonably have been expected to sustain.
Perhaps that is the real Abgesang. Not that crowdfunding has failed, but that Germany failed to turn Europe’s crowdfunding passport into the domestic market it was supposed to help create.
For FISMA and ESMA, this should be less a funeral than an experiment worth dissecting. The lesson is not necessarily to regulate less. It is to examine whether the rules create genuinely comparable competitive conditions, whether the national and European regimes protect investors in materially different ways, and whether the passport can deliver its promise when the legacy architecture remains in place.
The next European capital-markets initiative should ask an uncomfortable question before celebrating another single rulebook: Single rules for whom, and under what competitive conditions? This will be true for the EU-Inc as it will be for many other initiatives.
