NACE 66.3 – Fund Management Activities | Public Tenders

Definition: NACE 66.3 covers the management of investment funds, pension funds and other collective investment vehicles. In the public sector, this group is relevant for the administration of pension schemes, municipal foundation assets, pension funds and public promotional funds.

Legal basis: NACE Rev. 2 (Regulation (EC) No 1893/2006) · Last updated: January 2026

What does NACE 66.3 cover?

NACE 66.3 (Fund management activities) classifies capital management companies (KVG) and asset managers that administer investment portfolios on behalf of investors.

Group 66.3 within Section K (Financial and insurance activities) and Division 66 comprises one class:

Public contracting authorities in the NACE 66.3 area are professional pension schemes, municipal supplementary pension funds (ZVK), sovereign and stability funds, public foundations as well as promotional banks and reserve funds of public corporations.

Public Tenders: Sector NACE 66.3

The award of asset management mandates by public pension funds and pension schemes is among the highest-volume procurement operations in financial services.

Typical types of contract

• Investment management mandates: Discretionary asset management mandates for public pension schemes, pension funds and municipal foundations
• Overlay management: Risk and currency hedging strategies for institutional investors
• Alternative investments: Management of infrastructure investments, private equity mandates and real estate funds on behalf of public investors
• Municipal capital investment: Management of reserves, equalisation funds and special-purpose assets of cities and districts
• Promotional fund management: Administration of EU structural fund financial instruments (ERDF, ESF) by public administrative entities
• Stability fund administration: Fund management for public stabilisation and guarantee funds

Thresholds and procedure types

Like insurance services, fund management is subject to the simplified procurement regime under Articles 74–77 of Directive 2014/24/EU (Annex XIV). From a contract value of EUR 221,000, an EU-wide notice is required. Negotiated procedures are common in this segment and well justifiable under public procurement law (complexity of the service, need to develop the solution in dialogue).

Relevant CPV codes for NACE 66.3

Current tenders can be found on TED (Tenders Electronic Daily) as well as on national procurement platforms.

Who is NACE 66.3 relevant for in public procurement?

Public contracting authorities

Municipal supplementary pension funds (ZVK) such as the VBL (Pension Institution for Federal and Regional Authorities) or the BVK (Bavarian Pension Chamber) administer substantial assets and regularly tender investment mandates. Professional pension schemes (doctors, lawyers) are, as public corporations, likewise bound by public procurement law. Public foundations and university foundations procure asset management services for their endowment assets.

Companies and bidders

Capital management companies and asset managers participating in public tenders must meet the following requirements:

• Regulation: Authorisation as a KVG under KAGB or MiFID II licence for discretionary asset management
• Track record: Demonstrated investment results (performance) for comparable mandates across several market cycles
• AuM (Assets under Management): Minimum requirements for assets under management are often imposed as an eligibility criterion
• ESG integration: Increasingly, evidence of integrating sustainability criteria (SFDR, EU taxonomy)

NACE 66.3 in context: Section K and Division 66

• NACE K – Financial and insurance activities: Parent section
• NACE 66.1 – Activities auxiliary to financial services: Treasury, securities trading, debt management
• NACE 66.2 – Activities auxiliary to insurance and pension funding: Insurance brokerage
• NACE 64.1 – Monetary intermediation: Banking services

Frequently Asked Questions on NACE 66.3 and public tenders

Are pension schemes and pension funds bound by public procurement law?
Professional pension schemes are, in Germany, public corporations and thus public contracting authorities within the meaning of the GWB. They are subject to public procurement law when they procure services. The VBL and municipal ZVKs are likewise subject to public procurement law.

What applies to the award of EU structural funds by public bodies?
For the administration of ERDF or ESF financial instruments (e.g. loan or equity funds), EU procurement rules apply. The European Investment Bank (EIB) and its subsidiary EIF are subject to their own procurement principles, which reflect public procurement principles.

How are ESG criteria taken into account in fund management tenders?
Public contracting authorities increasingly integrate ESG requirements as technical specifications (e.g. exclusion of arms companies, coal exclusion) or as award criteria (ESG reporting quality, engagement strategy). The EU taxonomy and SFDR classification are used as a reference framework.

Can individual mandates below the thresholds be awarded directly?
Yes, provided the individual contract and the aggregated total demand do not exceed the thresholds. Public contracting authorities must, however, avoid the artificial splitting of contracts (section 3 VgV, section 2 UVgO).

Last updated: January 2026
All information is provided without guarantee. For legally binding advice, please consult a law firm specialising in public procurement law.