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Suitability Lab

Research, assessment logic and practical design for digital suitability.

What the research tested

A 2018 TUM thesis examined the questionnaires of 21 robo-advisors active in Germany and built a 31–36 question demonstrator. It compared the information gathered, consistency checks and proposed equity allocations for three sample investors.

What this lab uses: 11 core questions (10 scored) plus conditional sustainability details. It takes the three assessment dimensions and consistency logic from the thesis, but does not reproduce its 31–36-question questionnaire or its equity-allocation algorithm.

Using the thesis’s own assessment grid, providers met about 35% of the examined requirements on average; the best reached about 67%. More than half had no or weak consistency checks. The equity shares proposed to the same example investor differed by as much as 70 percentage points.

These figures describe the historical sample and the author’s method. They are not a current market benchmark or a finding about individual firms today.

From thesis model to governed system

1 / Collect

Loss-bearing capacity, knowledge and experience, objectives, risk tolerance and sustainability preferences, proportionate to the service.

2 / Verify

Check objective knowledge, contradictions, currency of data and missing answers before calculating any illustrative value.

3 / Match

Compare the resulting profile with actual product risks, costs, liquidity, target market and sustainability features. Document the decision and exceptions.

What the original scoring does—and where it stops

The thesis assigns up to ten points to individual criteria and weights them from one to five. It compares three averaging variants. Its preferred variant scales the weighted average to an illustrative equity percentage and applies the strictest cap derived from selected answers.

Similar outputs for three constructed investors do not validate a product recommendation. The 2018 framework predates the current ESMA suitability guidelines and the detailed collection of sustainability preferences. Our lab therefore exposes category scores and constraints without recommending an equity percentage or a product.

What a production system would still need

Research: Christoph Richter, MiFID 2 – Geeignetheitsprüfung bei Robo-Advisory: Rechtliche Grundlagen und praktische Umsetzung (TUM, 12.10.2018). Current reference points: ESMA suitability guidelines (2023) ↗ · BaFin MaComp, BT 7 (2024) ↗. The study is supplied by the project owner and is not hosted here.

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International market entry / Germany

Is Germany your next market?

Considering a local office, a branch or a standalone authorisation in Germany? The appropriate route depends on your home jurisdiction, activities and operating model. 3RMCN combines experience from complex supervisory projects with product, technology and delivery expertise: from entry strategy and key interfaces through to operational readiness.

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Supervisory perspectives

Familiar with several regimes

Experience in the context of CySEC (Cyprus), MFSA (Malta), FCA (United Kingdom), the European ESMA framework and MAS (Singapore). ESMA is not a national licensing authority.

International structuring

Incorporating offshore?

For incorporation in offshore jurisdictions, relevant specialists from the network can be involved. Jurisdiction, activities and regulatory obligations need to be considered for each project.