TWSE Market Insights

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In recent years, the global asset management industry has been undergoing an unprecedented transformation amid intensifying competition. Investors’ demand for product diversification, cost transparency, and trading convenience continues to rise, driving fund providers to seek innovative solutions. Against this backdrop, Exchange-Traded Funds (ETFs) have emerged as star products in capital markets thanks to their ease of trading, high transparency, and low costs. According to research by EY, global ETF assets under management (AUM) are projected to surpass USD 25 trillion by 2030, signaling a new era of prosperity for the industry.

However, for many small- and mid-sized asset managers, investment advisors, and even emerging fintech firms, establishing their own ETF issuance platforms remains a daunting challenge. High initial capital requirements, complex regulatory approvals, limited counterparty networks, and heavy operational costs serve as significant barriers to entry. To address these challenges, the concept of the White Label ETF has emerged as an important innovation in the asset management industry.

White label ETF providers offer “one-stop” services that enable aspiring issuers to quickly, cost-effectively, and compliantly launch listed ETFs. This model breaks the monopoly of large asset management companies and multinational financial institutions over ETF issuance, creating market opportunities for a broader range of participants, including smaller firms, financial advisors, and fintech startups.

This paper will provide an in-depth analysis of the definition, operating mechanism, global developments, and key challenges of white label ETFs, offering readers a comprehensive understanding of this emerging model.

A White Label ETF[1] is a model in which ETF issuance and management are outsourced to a professional third-party platform (a white label platform). Asset managers, investment firms, or issuers do not need to build a full-scale ETF infrastructure themselves. Instead, they delegate complex back-office functions—such as regulatory compliance, operational setup, custody, coordination with market makers, and fund administration—to the white label platform. This allows issuers to focus on investment strategy design and brand marketing, while bringing ETFs to market quickly.

In the United States, launching an ETF from scratch requires substantial capital and a lengthy preparation period. To build out the necessary infrastructure—capital markets network, compliance procedures, marketing, custody arrangements, business operations, and professional trading teams—an initial investment of approximately USD 600,000 to 1,000,000 is typically required, with ongoing annual fixed costs of USD 300,000 to 500,000. The process generally takes 6 to 12 months. This in-house model is more suitable for large institutions that seek full control of the ETF issuance process.

By contrast, the white label ETF model offers a more cost-efficient and streamlined pathway. Through white label platforms, funds can be launched within 3 to 5 months, with initial costs of about USD 50,000 to 75,000 and annual expenses ranging from USD 200,000 to 260,000. This approach not only reduces traditional ETF launch costs—often hundreds of thousands to over a million dollars—by up to 90%, but also allows issuers to concentrate on investment strategy and marketing.

The white label ETF model is particularly well-suited to issuers focused on thematic or strategy-driven products, as well as smaller or newly established asset managers. With its lower barriers to entry and faster time to market, the model enables issuers to prioritize investment ideas and distribution without bearing heavy operational and regulatory burdens. At the same time, it provides firms entering new markets with a lower-risk testing ground, allowing them to validate investor demand at a modest cost before deciding whether to transition to a self-built platform for greater autonomy as their funds scale up.

[1] Tidal. What is a White Label ETF Provider? https://tidalfinancialgroup.com/launching-an-etf-white-label-could-be-the-answer/?utm_source=chatgpt.com

First, in terms of role allocation, the brand owner (issuer) and the white label platform form a complementary partnership. The brand or investment advisor is primarily responsible for providing the investment concept, designing the fund’s investment strategy, and making related investment decisions. They also determine the ETF’s market positioning, thematic focus, underlying assets to be tracked, and the overall investment narrative, while leading subsequent marketing efforts and investor communications. In other words, the core value of the brand lies in its investment expertise and market influence.

In contrast, the white label platform focuses on regulatory and infrastructure-related functions. It provides existing legal structures—such as established trust frameworks in the U.S. or UCITS fund platforms in Europe—so that new funds can be quickly integrated into a ready-made system, avoiding the need for issuers to build fund structures from scratch. White label platforms also handle the drafting and filing of regulatory documents, fund registration, exchange listing applications, and contract management, as well as coordinating with external participants such as custodians, accounting firms, Authorized Participants (APs), market makers, and index providers. Additionally, the platform maintains day-to-day fund operations, ensuring ongoing disclosure, website maintenance, and regulatory compliance.

The design of the regulatory and legal framework is one of the key factors determining the success of white label ETFs. In the U.S., white label platforms must incorporate new ETFs into an existing trust structure under the Investment Company Act of 1940 and SEC Rule 6c-11, ensuring compliance and meeting market transparency requirements. In Europe, most products follow the UCITS framework and the listing requirements of local exchanges. Here, white label platforms often leverage management companies and existing fund platforms to meet cross-border distribution and regulatory standards, thereby expanding their market reach.

Another crucial component is capital markets infrastructure. To ensure that the ETF’s creation and redemption process runs smoothly—and that the fund’s market price closely tracks its Net Asset Value (NAV)—white label platforms typically establish partnerships with Authorized Participants, market makers, and exchanges. Moreover, the quoting activities of market makers enhance secondary market liquidity, improving investors’ trading experience.

In terms of operations, white label ETFs follow a relatively comprehensive set of steps. The process begins with product design, where the brand owner proposes the investment concept, and the white label platform conducts a feasibility analysis—assessing factors such as liquidity, index replicability, and licensing requirements. The next stage is legal and regulatory setup, where the platform leverages existing legal entities to prepare the prospectus, regulatory filings, and exchange listing applications.

Once the legal framework is in place, the white label platform coordinates the external service supply chain. This includes custodians responsible for asset safekeeping and settlement, fund accountants who calculate the daily Net Asset Value (NAV), and transfer agents (TAs) who manage ETF share registration and circulation. For passive ETFs, index providers must grant licenses and supply benchmark data. When the fund is officially listed, the platform also works with exchanges, Authorized Participants, and market makers to ensure sufficient liquidity in the secondary market.

Post-listing, the ETF’s day-to-day operations remain heavily supported by the white label platform. This covers daily portfolio disclosure, the publication of intraday indicative NAVs (iNAVs), updates to websites and investor documents, and ongoing compliance with SEC or UCITS disclosure requirements. This continued maintenance allows the brand owner to focus primarily on investment decisions and marketing efforts.

From a business model perspective, white label ETFs typically adopt a “fixed fee plus variable fee” structure. The brand owner pays a fixed platform usage fee covering legal setup, compliance processes, and basic fund operations. In addition, the platform may charge a percentage-based fee tied to the fund’s AUM, or collect variable service fees for activities such as marketing and distribution. Compared with building a full in-house ETF platform, the white label model significantly shortens the fund launch timeline (usually 3 to 5 months), reduces initial costs, and spreads part of the operational risk to the platform.

Overall, the operational framework of mainstream white label ETFs in the U.S. and Europe is one of highly specialized division of labor. By leveraging the platform, brand owners lower barriers to entry and can transform investment ideas into listed ETF products more quickly and efficiently. Meanwhile, the white label platform provides comprehensive support through its legal structures, regulatory expertise, and capital market networks. This model not only fosters greater innovation and diversity in the ETF market but also opens the door for small- and mid-sized asset managers and new entrants to participate in the ETF ecosystem.

1. United States

In the U.S. ETF market, the rise of white label platforms has been driven by both structural trends and evolving market demand.

First, regulatory easing created a key opportunity. In 2019, the U.S. Securities and Exchange Commission (SEC) adopted Rule 6c-11, which simplified ETF registration and operations, reducing compliance barriers. For white label platforms, this not only shortened the ETF launch timeline but also eased the cost pressures on emerging asset managers.

Second, growing demand for thematic investing has fueled the expansion of white label ETFs. Whether in artificial intelligence, blockchain, cybersecurity, or space exploration, investors seek exposure to emerging industries and long-term trends. However, these themes often lack broad market foundations, making large traditional asset managers less willing to commit resources. White label platforms, by contrast, provide a low-barrier pathway for smaller investment advisors or specialized research firms to transform investment strategies into ETFs, allowing them to respond quickly to market hotspots.

Third, the inherent advantages of ETFs continue to attract more investment advisors. Compared with traditional mutual funds, ETFs offer higher tax efficiency, greater liquidity transparency, and lower management fees. For many small- and mid-sized advisory firms, launching an ETF is not only a natural extension of their asset management business but also a way to strengthen brand visibility and expand their client base. White label platforms have thus become the ideal gateway for these firms to enter the ETF market.

Among the key players:

• Tidal Financial Group is one of the largest and most significant white label ETF platforms in the U.S. According to its website, as of the end of July 2025, it manages over 225 ETFs with more than USD 40 billion in AUM. Tidal provides full-service back-end support—including compliance, trading execution, fund accounting, and coordination with market makers—and is especially favored by thematic ETF issuers for its ability to efficiently bring concepts to market.
• Alpha Architect emphasizes transparency and investor education, serving mainly independent advisors (RIAs) and investors focused on quantitative strategies. Its platform helps small issuers launch ETFs through flexible structures, making it particularly suitable for research-driven products.
• ETF Managers Group (ETFMG) was an early entrant in the U.S. white label ETF space, known for launching thematic ETFs such as early cannabis and cybersecurity funds. Although the firm has faced legal disputes and partnership controversies during its development, it remains recognized as an important pioneer in advancing white label ETFs.

2. Europe

The development of white label ETFs in Europe started somewhat later than in the U.S., but the drivers are equally strong.

First, the UCITS framework provides the institutional foundation for cross-border fund distribution in Europe. With its regulatory emphasis on transparency, investor protection, and passporting, ETFs approved in financial hubs such as Luxembourg or Ireland can be marketed across the entire EU. White label platforms can therefore leverage the UCITS framework to deliver “one-stop” solutions for small- and mid-sized asset managers.

Second, European investors’ acceptance of low-cost and passive investing has risen rapidly. Over the past decade, inflows into passive funds have significantly outpaced those into active funds, pushing many asset managers to seek faster entry into the ETF space. Against this backdrop, white label platforms have emerged as the most efficient way for traditional firms to outsource their ETF operations.

Third, demand for thematic and ESG investing is especially strong in Europe. The region has long been a leader in sustainable finance, and the EU’s Sustainable Finance Disclosure Regulation (SFDR) requires funds to disclose ESG characteristics. White label platforms thus help issuers design and launch compliant ESG or thematic ETFs, quickly responding to market trends.

The most prominent European white label platform is HANetf. According to its July 2025 press release[2], HANetf has grown rapidly in recent years, with AUM exceeding USD 7.7 billion. Since January 1, 2025, its AUM has increased by 63.3%, far outpacing the 17.7% growth of the broader European ETF market. HANetf has supported the launch of multiple innovative products, including Europe’s first gold ETC issued by the Royal Mint and the first bitcoin ETP listed on Deutsche Börse Xetra. In July 2025, Citi invested in HANetf, further underscoring the platform’s growing market influence.

According to the Financial Times[3], Citi not only invested in HANetf but also launched its own white label platform—Citi Velocity ETFs—in early 2025. The initiative aims to help large institutions enter the European ETF market with shorter launch timelines. Citi is already an Authorized Participant, market maker, custodian, paying agent, and transfer agent for ETFs, making its platform distinct from existing white label providers. By leveraging its broad service capabilities, Citi seeks to achieve economies of scale and reduce ETF launch times from one to two years down to just three to six months.

3. Asia

The Asian white label ETF market has developed more slowly. According to a press release from the Tokyo Stock Exchange[4], Japan introduced the system in June 2025, with services provided by JAMP Fund Management, a subsidiary of the Japan Asset Management Platform (JAMP). The initiative aims to lower barriers to ETF issuance and attract more innovative investment ideas to the market, marking a shift in Japan’s recognition of the convenience offered by white label ETFs.

This development is expected to drive greater diversity in ETF products listed on the Tokyo Stock Exchange (TSE). These include domestic ETFs adopting an “ETF of ETFs” structure—investing in ETFs already listed in other countries—as well as ETFs established by local asset management firms that previously operated only as investment advisors. By leveraging the white label ETF mechanism, the TSE can more easily bring new investment concepts to market, offering investors a broader and more attractive range of products.

JAMP Fund Management has introduced three white label ETF service structures, designed to help different types of asset managers enter the Japanese ETF market more efficiently. The three structures are described as follows:

(1) ETF of ETFs Structure

This structure allows an asset management company to establish a Japan-registered ETF through JAMP Fund Management, with the fund primarily investing in the company’s ETFs already listed in other countries. JAMP Fund Management is responsible for setting up and managing the Japan-registered ETF—covering fund establishment, back-office operations, regulatory filings, and communications with the exchange—while also coordinating with the asset management company. The asset manager, in turn, remains responsible for managing its ETFs listed overseas.

This “ETF of ETFs” model enables asset managers to leverage their existing overseas ETFs as underlying assets, without the need to build a full in-house portfolio management team. It not only reduces operational costs but also facilitates the rapid introduction of globally diversified investment strategies into the Japanese market.

(2) Investment Advisory Structure

Under this framework, the asset management company primarily acts as an investment advisor, while the actual ETF setup and investment management are handled by JAMP Fund Management. JAMP not only establishes and manages the ETF but also assumes responsibility for investment management, effectively serving as the operating entity. The asset manager does not directly manage the fund’s assets but instead provides investment recommendations to JAMP.

The benefit of this structure is that the asset manager does not need to handle fund setup, operations, or full-scale investment execution. They can still launch an ETF under their own brand and retain some strategic influence. For small- and mid-sized firms with limited resources or without a complete operational infrastructure, this offers an effective, low-barrier entry into the ETF market.

(3) Investment Management Sub-delegation Structure

In this model, JAMP Fund Management oversees the ETF’s establishment and administrative operations, while delegating the investment management function back to the asset management company. The asset manager is then responsible for executing the investment strategy, deploying capital into equities, bonds, and other assets.

By clearly dividing responsibilities—operations handled by JAMP, investment decisions made by the brand owner—this structure creates a compliant and cost-efficient channel for ETF issuance. It allows asset managers to expand their product lineup while addressing diverse investor needs.

 
[2] HANetf receives growth capital investment from Citi as institutional appetite for entering the ETF market soars. https://white-label.hanetf.com/insights/hanetf-receives-growth-capital-investment-from-citi-as-institutional-appetite-for-entering-the-etf-market-soars/?utm_source=chatgpt.com 
[3] Financial Times 2025 Citigroup unveils plan to power active ETF surge in Europe. https://www.ft.com/content/a62af72d-cc86-4e32-898c-01b444306709?utm_source=chatgpt.com 
[4] Tokyo Stock Exchange 2025 Entry of the White Label ETF Provider. https://www.jpx.co.jp/english/corporate/news/news-releases/0060/20250606-01.html 

While white label ETFs offer many advantages to asset managers—such as reducing issuance costs, shortening time-to-market, and improving operational efficiency—they still face significant challenges, including insufficient scale and liquidity, branding and marketing limitations, cost–revenue pressures, and regulatory hurdles. For example, Goldman Sachs launched its ETF Accelerator platform in 2022 and expanded into Europe in 2024, but by May 2025 announced plans to gradually wind down the platform and transfer related services to specialized provider Tidal Financial Group, choosing instead to focus on higher-margin business areas. The main challenges currently facing white label ETFs are outlined below:

1. Insufficient Scale and Liquidity

Although multiple providers now operate in the U.S. and European white label ETF markets, their combined AUM still represents only a small share of the overall ETF industry. Most white label ETFs are niche, thematic, or strategy-based products. If they fail to attract assets quickly, they often suffer from inadequate liquidity. This can result in difficulties for investors entering or exiting positions, wider bid–ask spreads, and ultimately threaten the fund’s viability. In short, while white label ETFs solve the “technical barrier” of issuance, the real challenge lies in attracting seed capital and early investors, and ensuring active engagement from market makers to support liquidity.

2. Branding and Marketing Limitations

Compared with traditional asset management giants like BlackRock (iShares) or Vanguard, white label ETF issuers are typically smaller advisory firms or startups without strong brand recognition. This makes it harder to gain traction with institutional investors and secure placement on wealth management platforms. Marketing costs can also be prohibitively high for smaller firms.

Even after listing, ETFs without broad distribution channels or broker support struggle to reach institutional investors or inclusion on major wealth management platforms. In Europe, these challenges are compounded by market fragmentation—differences in language, taxation, and regulations—making widespread adoption even more difficult.

3. Cost and Revenue Pressures

Although the white label model lowers the initial barrier to entry, platforms still charge fixed fees. In a highly competitive ETF market characterized by low expense ratios, even successful launches may struggle to reach breakeven quickly. If an ETF fails to achieve sufficient scale, ongoing fees can erode revenues, making it difficult for issuers to sustain operations.

4. Regulatory and Supervisory Challenges

In the U.S., while Rule 6c-11 has simplified certain procedures, strict requirements remain in areas such as compliance, disclosure, and market-making arrangements. In Europe, the UCITS framework allows cross-border distribution but imposes multiple layers of regulation, ESG disclosure obligations, and tax compliance, all of which increase administrative costs. Although white label platforms help reduce entry barriers, issuers ultimately bear the risks related to investment advisory responsibilities, investor protection, and cross-border sales regulations.

Globally, white label ETFs have gradually evolved from a convenient tool for small and mid-sized asset managers into an important model in international capital markets. The mature experiences of the U.S. and European markets show that, through white label platforms, asset managers can quickly launch ETFs covering thematic investments, quantitative strategies, ESG, and even actively managed approaches, while integrating product design, compliance, operations, and distribution. The entry of large financial institutions such as Citigroup further underscores the market value and scalability of the white label model.

Although Asia is still in its early stages, Japan’s launch of its first white label ETF platform in 2025 demonstrates future potential, providing asset managers with a more accessible issuance channel. Looking ahead, white label ETFs are expected to expand beyond traditional equity and fixed income into emerging asset classes such as private markets, blockchain, and digital assets, offering investors a broader range of choices. However, challenges remain—including limited scale and liquidity, branding and marketing hurdles, cost–revenue pressures, and regulatory complexity—highlighting the need for ongoing optimization and innovation in the years to come.