BaFin Stops Ventus Energy: Which P2P Platforms Are Now At Risk?

Ventus Energy is history. The BaFin order of 5 May 2026, which required the platform to immediately cease and wind down the deposit business it had been operating without authorisation, has set off a chain reaction.

As a result, on 11 June 2026 Ventus Energy announced that normal operations had ceased and that an orderly wind-down had been initiated.

A question that I have been asked fairly often since then: Which other P2P platforms might now be affected as well?

To answer this, I first took a close look at the precise allegations against Ventus Energy and then analysed the contractual structures and user agreements of various platforms.

This article is an attempt to answer how investors can try to assess the “BaFin risk” themselves, and how I read the situation at Bondora, Monefit SmartSaver, PeerBerry, Income Marketplace, Devon, Asterra Estate and Triple Dragon.

---

BaFin Stops Ventus Energy

By order dated 5 May 2026 (made public on 18 May 2026), BaFin directed that Ventus Energy Group OÜ, based in the Estonian capital Tallinn, must immediately cease, and without delay wind down, the deposit business it had been operating without authorisation.

Why did BaFin intervene in the case of Ventus Energy?

In the view of the German financial supervisor, Ventus Energy Group OÜ had, on the basis of loan agreements with investors in Germany, accepted unconditionally repayable funds without the repayment claim being securitised in the form of bearer or order debt certificates.

In doing so, Ventus Energy had operated a deposit business within the meaning of section 1 (1) sentence 2 no. 1 of the German Banking Act (Kreditwesengesetz, KWG) without the required authorisation.

The wind-down order then obliged Ventus Energy Group OÜ to repay the funds accepted from German investors without delay.

Deposit Business or Purchase of Claims?

The central allegation against Ventus Energy is that the platform operated a deposit business without authorisation. So, let’s look at what exactly counts as a deposit business and which criteria have to be met.

The key provision here is section 1 (1) sentence 2 no. 1 KWG. It reads:

“the acceptance of funds from others as deposits or of other unconditionally repayable funds from the public, irrespective of whether interest is paid, provided that the claim for repayment is not securitised in the form of bearer or order debt certificates (deposit business)”

Im simple terms, a deposit business exists when two features come together:

First: The acceptance of unconditionally repayable funds. That means, someone accepts money from retail investors and owes its repayment without that repayment being tied to any conditions, regardless of whether a project is running, whether borrowers pay, or how the company is doing financially.

Second: No securitisation in bearer or order debt certificates. In other words, the claim is not a security.

Two Models, Two Risk Profiles

There are essentially two models in the P2P market.

Model 1: Self-Financing via Direct Loans. The platform, or its group, raises money to finance its own projects, structured as loans. The investor therefore lends the money directly to the platform group, which thereby becomes the unconditional repayment debtor itself.

Model 2: Purchase of Claims (Assignment). Here, the investor buys a claim against a third party. The platform is merely an intermediary and administrator, not the debtor. No money is accepted as the platform’s own deposit. Instead, a purchase of claims is arranged.

The decisive question is therefore not necessarily whether a platform is regulated or not, but who is the debtor of my investment, and whether repayment is unconditional.

This raises two simple questions that I use to examine every platform:

• Do I get my money back unconditionally from the platform? Or is repayment tied to conditions (for example, that in an insolvency I rank behind everyone else)?
• Does my money end up in the platform’s own assets? Or am I only buying a claim against a third party, while my money is held separately?

If the platform is itself the debtor and repayment is unconditional, we are in the Ventus camp. If I buy a claim against a third party and repayment depends on that party’s ability to pay, we are in the claims-purchase camp. With this lens, I will now go through the individual P2P platforms.

---

The Clean Route: Regulated P2P Platforms

One clean solution is to take the licensed, regulated route. So, let’s first look at the “safe” P2P platforms.

MiFID Investment-Firm Licence

The P2P platforms based in Latvia hold licences as investment firms and issue securitised notes or asset-backed securities. These include Mintos, TWINO, Viainvest, Debitum, Nectaro and Indemo.

Once the claim is securitised, the base prospectus regime applies, and not the concept of a deposit.

ECSP Crowdfunding Licence

The second route is the European crowdfunding licence (ECSP), held by LANDE, Crowdpear, Estateguru and Lendermarket, among others. This licence permits the intermediation of genuine, unconditionally repayable loans.

The ECSP Regulation also prohibits financing one’s own projects or allowing related parties as project owners. Instead, an ECSP platform must commit to acting as a neutral intermediary between third-party project owners and its investors.

So, anyone raising money for their own companies cannot take this route at all, and inevitably ends up in the unregulated direct-loan model. And that is exactly where the next group of platforms comes in.

---

The WLS Platforms: Same Structure as Ventus Energy?

The company White Label Solution (WLS; https://whitelabelsolution.eu/) is a provider that supplies the platform technology behind Ventus Energy and other platforms such as Devon, Asterra Estate and Triple Dragon. Its CEO and shareholder is the Latvian Toms Abele, former head of marketing at Ventus Energy.

The obvious assumption: Same technology, same legal structure, same risk.

To check this, I looked at the loan agreements of Devon (version dated 06.05.2025) and Asterra Estate (version dated 31.07.2025). Both follow a common structure: The investor grants the platform company a loan directly, the platform passes the money on to its own project or development company, and the repayment claim is directed unconditionally against the platform itself.

An important note: Both contracts are said to have been revised in the meantime. On my enquiry, neither Devon nor Asterra provided me with a current version. Both platforms pointed out that the contract documents are accessible only to investing clients.

My analysis therefore relates only to the versions named above that are available to me. Whether today’s contract version is structurally identical, I cannot verify. The fact that a platform keeps its loan agreements under wraps from prospective investors and only discloses them after one has invested is in itself a transparency point worth keeping in mind.

Devon

With Devon, the situation is relatively clear-cut. WLS CEO Toms Abele stated in the official Devon Telegram chat himself:

“The platform is not regulated. The main reason is: the crowdfunding license does not allow raising funds for one’s own companies. MJL raises funds only for its own companies, structuring these as loans (not investments). Basically, the regulation and legal framework are the same as with Ventus Energy platform.”

The contract version available to me (06.05.2025) confirms it word for word. The investor’s debtor is Devon OÜ itself. The company undertakes to repay the loan amount by the end of the term. The claim ranks expressly pari passu with other creditors (section 7.2.4), so there is no subordination (Rangrücktritt) that would turn the whole thing into an investment product (Vermögensanlage).

Collateral is not provided in the standard case (section 9: no security without a separate annex).

Devon takes the money in order to pass it on to its group’s own development company (SG Jurmala Estate SIA, project “AMBER PARK”, part of the MJL group). MJL Enterprises SIA provides a group guarantee.

In plain terms: Unconditionally repayable funds from the public, no securitisation, no authorisation. From my perspective, that meets all the features of a deposit business. Subject to any subsequent contractual changes, Devon is therefore the case to which BaFin’s reasoning most directly applies.

Asterra Estate

According to the loan version available to me (31.07.2025), Asterra Estate belongs in the same camp as Devon. The investor’s debtor is Asterra Estate OÜ itself. The company undertakes to repay the loan amount by the end of the term. Here as well, the investor’s claim ranks expressly pari passu (section 8.2.4). In other words, no subordination.

Asterra passes the money on to its own subsidiary (8 Solutions SIA, expressly “a subsidiary of the Borrower”), which holds the “Guest House” project within Asteres Village. Asterra additionally guarantees repayment itself.

One difference from Devon: Asterra’s loans are secured by real estate, whereas Devon is unsecured in the standard case. That would improve recovery prospects in a worst-case scenario. It does not, however, change the regulatory classification.

Based on the version I examined, Asterra Estate therefore clearly belongs in the Ventus camp. But keep in mind: The contract version may have been amended in the meantime and may differ from the one available to me.

Triple Dragon Funding

Triple Dragon also runs on WLS technology, but in my view belongs structurally in a completely different camp. The platform’s operator, Triple Dragon Funding S.a.r.l. based in Luxembourg, handles its loan agreements via a purchase of claims.

This means that the investor acquires, by assignment, a claim against a third party (game and app studios), transferred by an external loan originator. So, this is not a direct loan to the platform itself.

The terms expressly declare the funds paid in to be “not a deposit or any other type of taking of repayable funds”. The funds are held separately from the platform’s own assets, and repayment is made dependent on the borrower’s performance.

As I understand it, BaFin’s reasoning against Ventus Energy does not apply in this case.

---

The Claims Purchasers: Why the KWG Risk Does Not Apply

This brings us to the next group, the classic claims purchasers. Their business model is almost always identical and is defined by the following features:

• the investor buys a claim against third parties,
• the platform is not the debtor,
• client funds are held separately,
• repayment is tied to the ability of the borrower or the loan originator.

Bondora Go & Grow

Bondora Go & Grow is the product with the most deposit-like appearance: A fixed target return of 6% p.a., daily interest, daily availability. The product is operated by Go&Grow OÜ, working with licensed loan originators in the background.

Anyone who invests in Go & Grow does not enter into a loan agreement with Bondora and does not lend the platform any money. Instead, investors become the legal owner of fractions of a large pool of loan claims that Bondora holds against the borrowers. So, your money does not become a deposit with Bondora, it buys claims that belong to you as the investor.

The decisive point here is that there is no unconditional repayment claim against Bondora. Liquidity arises from the repayment of loans, which is expressly not guaranteed. Uninvested money is also held in a trust structure, separate and non-interest-bearing.

For that reason, there is no parallel to Ventus Energy. On the contrary: Through the ownership of segregated claims, Go & Grow is structurally one of the more cleanly set-up products in this comparison.

Monefit SmartSaver

Monefit SmartSaver is essentially a copy of Bondora Go & Grow: Purchase of claims, up to 7.5% return in the flexible main account, daily interest.

Technically, here too the investor acquires “SmartSaver Claims” via an assignment agreement, that is claims from consumer-credit agreements, which Monefit then administers on the investor’s behalf.

On the KWG-level, the result is therefore the same as with Bondora: No parallel to Ventus Energy.

PeerBerry

PeerBerry has one of the cleanest claims-purchase contracts and clearly belongs in this camp. The operator of the platform is PEERBERRY d.o.o. in Croatia. On the marketplace, the investor buys claims from the loan originator against a third party (the borrower).

Investor funds are held separately and PeerBerry acts as an authorised representative. Repayment is tied to the loan originator’s payments and is expressly not guaranteed.

Income Marketplace

Income Marketplace is another textbook example of the claims-purchase model: Via an assignment agreement, the investor acquires claim rights from loans that are arranged by the marketplace and provided by external loan originators. The operator in this case is Income Company OÜ in Estonia.

Crucial: Income is not the debtor of the acquired claims. The protection (buyback guarantee) is also offered by the loan originator, not by Income Marketplace. Uninvested funds are held in separate accounts.

---

Conclusion: Which P2P Platforms carry the “BaFin-Risk”?

Contrary to what is claimed in other forums and blogs, in my view the decisive risk axis is not the question “regulated or not?” but “who is my debtor, and is repayment unconditional?”

On that basis, the “BaFin-risk platforms” sort themselves out almost automatically.

In the Ventus camp are the WLS self-financers, which raise money for their own companies as loans. For Devon and Asterra, the loan agreements available to me confirm this. In both cases the platform OÜ is itself the debtor, repayment is unconditional and expressly pari passu (no subordination), and the money is passed on to the group’s own project company.

Structurally, this is exactly the same pattern as at Ventus Energy, albeit with the caveat that neither platform disclosed a current, possibly revised contract version to me.

Outside this risk are the claims purchasers: Bondora, Monefit, PeerBerry, Income Marketplace, and Triple Dragon. These platforms do not carry the KWG deposit risk. Their real risks lie elsewhere: loan-originator creditworthiness, concentration risk, liquidity, and so on.

What does that mean in practice for investors’ due diligence? If a platform advertises that it raises money for its own projects and structures this as a “loan”, without a licence and without securitisation, then that is exactly the pattern BaFin caught at Ventus.

If, on the other hand, you buy a claim against a third party, the risk shifts from supervisory law to that third party’s creditworthiness. Both need to be assessed, but they are different questions.

And that is precisely the point that often gets lost in the agitated debate after the Ventus order: A loud “which platform is next?” helps no one. A sober look into the contracts, on the other hand, does.