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UCITS ETFs: Building the Operating Model that Wins

Article  •  May 26, 2026
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HIGHLIGHTS

  • UCITS ETF AUM has reached $3.5T with sustained inflows, driven by retail expansion, product innovation, and global demand
  • Success hinges on defining ETF role (core vs complementary), competitive positioning, and path to scale early to avoid misaligned investment and execution
  • Winning platforms require deliberate choices across route-to-market (in-house / hybrid / white-label), liquidity, distribution, and infrastructure scalability

The UCITS Exchange-Traded Funds (ETFs) market presents a compelling and expanding opportunity for asset managers. However, entry is complex, and success is far from guaranteed. For some, ETFs are a strategic imperative, reflecting a structural shift in how investment strategies are delivered. For others, they serve as a tactical response to changing client preferences or increasing competitive pressure.

For a growing cohort of boutiques and specialist managers, ETFs offer a new distribution channel for differentiated strategies that were previously confined to traditional fund structures.

Regardless of motivation, entering the UCITS ETF market is a consequential decision. ETFs require purpose-built infrastructure, specialized capabilities, and a carefully designed operating model, encompassing everything from fund structuring and domicile to distribution, servicing, and secondary market support. Getting these elements right from the outset has a material impact on the speed to market, cost efficiency, and long-term sustainability of an ETF platform.

This paper, co-authored by Deloitte Luxembourg and Citi, is designed to help managers navigate these decisions. The analysis reflects experience gained from working with a broad range of asset managers at various stages of ETF adoption, and is informed by the operational and structural realities of bringing ETF strategies to market.

The document is structured around a three-stage framework:

Stage Focus Key Questions 
1. Define your identity Strategic roleStrategic role of ETFsTactical or core? Passive or active?
Who is the client?
2. Define your route to marketHow to establish ETF capabilityIn-house, outsourced, or hybrid?
3. Define your operating model designExecution infrastructureOrganizational structure, distribution
model, domicile, product features, service
provider strategy?

UCITS ETFs: Building the operating model that wins

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