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Commerz Real’s Huzarski: “Regulatory constraints sit at odds with society’s ambition to move forwards to a sustainable future”

Published: 20 December 2022

KlimaVest is the first impact fund in Germany focusing on real assets for private investors. Tobias Huzarski, head of impact investment at Commerz Real, the fund’s manager, talks to Impact Investor.

Tobias Huzarski: “We strongly believe that the positive causal relationship between impact investing and strong investment returns has never been clearer.” | Commerz Real

In brief

  • KlimaVest is Germany’s biggest climate impact fund aimed at individual investors
  • For each €10,000 deployed into renewable energy assets, the fund seeks to mitigate 3.5 tonnes of CO2 equivalent per annum
  • Renewables are very much the current focus, though the team keep a keen eye on all new technologies
  • Huzarski rails against regulatory constrains preventing the deployment of more capital to fund climate solutions

Commerz Real launched KlimaVest, its first impact fund for private investors, in October 2020. Tobias Huzarski, head of impact investment at Commerz Real, tells Impact Investor there were several drivers behind the move.

“Of course most importantly we believe we’re at a time where it is a moral obligation for all of us in the investment world to focus on climate mitigation. Beyond this, we strongly believe that the positive causal relationship between impact investing and strong investment returns has never been clearer. Finally, for us it was very apparent that private investors are looking for ways to put their capital to work and have very few if any properly managed funds in which they can.”

Huzarski argues that far too many of the existing impact products such as exchange traded funds (ETFs) are “simply moving capital around horizontally”. He adds: “The scope for real world impact is limited. There is a clear need for funds which are moving capital vertically and actually investing the money an investor puts in to have positive environmental change.”

The fund is now close to reaching €1bn. “There is no question that the energy crisis in Germany is super relevant here. It used to be the case that we considered energy free and unlimited, and the crisis has made us aware that it is neither. The case for renewables has been made much more strongly, and, clearly, they are the best hope that we have [for energy] to be exactly those two things.”

Fund structure

KlimaVest has an  European Long-Term Investment Fund (ELTIF) structure which is only available to semi-professional investors with more than €100,000 of capital. The minimum investment into the fund is €10,000, and although it is a Luxembourg structure and could be available throughout Europe, Commerz Real currently only markets the fund in Germany.

Huzarski expects these minimum investment thresholds to be lowered as a result of current EU negotiations on reforming the ELTIF structure.

“Most of our Commerz Real’s funds have some kind of sustainability twist”, he says. The key differentiator for KlimaVest, according to Huzarski, is that it is their first impact fund with a very specific ambition built into its DNA. “Our overriding objective is to mitigate climate change. And we have a very clear KPI for measuring that. For each €10,000 which are deployed into renewable energy assets, we seek to mitigate 3.5 tonnes of CO2 equivalent per annum.”

The team are required from a regulatory standpoint to use established methods to calculate this from publicly available data. But also, for each and every project, there is third party due diligence from external providers to ensure that that project complies with this criteria.

Huzarski says: “Climate mitigation is our number one objective, but we don’t want to achieve that by treading on the toes of other important objectives such as biodiversity, the circular economy, or water resources. So we seek to combine this principal objective with two others: to consider the environmental implications more generally and also to look at any investment from a social and governance perspective, and to consider the human impact and make sure our investments are in line with social and governance standards.”

A focus on renewables

The fund aims to “build a portfolio of renewable energy generation assets as well as sustainable infrastructure, mobility and forestry assets”.

Commerz Real spent some time researching all of the different technologies that are available to mitigate climate change and considering which of them are scalable. “For example we looked at tidal power, but came to the conclusion that this was simply not a scalable alternative. The main technologies we see as really scalable are wind, solar, biomass and geothermal.”

The fund doesn’t have a preconceived allocation between the different technologies, but does look to diversify in terms of technology, geography, and the developers the team work with.

Huzarski is also keenly on the lookout for new approaches and technologies. “Within solar we’re also interested in the agri-solar space. By this I mean where we put solar panels sitting on stilts on agricultural land and actually grow something underneath. In other words you might be growing potatoes while generating electricity.”


Huzarski believes “we can’t offset our way into a net-zero future. It’s all about bringing renewables to the fore. It’s about the real economy, not just bookkeeping.”

For this reason, he sees many problems with the current carbon credits regime. “There are not enough projects for all the transactions that are required. Companies are often forced to do the work and research to find smaller, and not necessarily institutionally managed projects.”

Huzarski also believes the government has a vital role to play in getting out of the way. “Capital will not solve the energy transition alone it does need public-private collaboration. It is clear from the work that we are doing that the deployment of capital is somewhat constrained by the red tape placed on renewable energy projects.”

This includes when it comes to funds such as KlimaVest and the constraints that are placed on the fund itself. “I think our desire to make this fund as inclusive as possible is very constrained by regulatory issues.” For example, these currently still force KlimaVest to require the semi-professional investor qualification mentioned above.

He concludes: “These constraints sit at odds with society’s ambition to move forwards to a sustainable future.”

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