Scalable Capital

Key Findings

• Economic: In October 2026, Scalable-owned justETF advertised Scalable Capital savings plans for Elbit Systems shares. The listing is consistent with Scalable’s general savings-plan offering, but successful account-level activation, execution and customer investment volumes were not independently verified.^{1, 2, 3, 4}
• Economic: BlackRock’s latest reviewed annual filing identifies Scalable Capital as a minority investment. BlackRock separately owns the Israel-active Kreos lending business; those operations establish a shareholder-level relationship, not Israeli assets owned by Scalable Capital or a verified onward transfer of Scalable profits.^{5, 6, 7}
• Economic: Borrower filings distinguish continuing exposure from repaid debt: BioLineRx reported an economically active BlackRock/Kreos loan at December 2025, while PolyPid reported full repayment of its outstanding Kreos loan balance on 4 May 2026.^{8, 9}
• Not found: The military and digital audits report No public evidence identified of Scalable Capital supplying Israeli military equipment, military technology or settlement digital infrastructure. Its documented banking, exchange and AI services have civilian financial functions.^{10, 11, 12}

Target Profile

Executive Summary

Scalable Capital is a Munich-headquartered European investment and banking platform. Its documented services encompass brokerage, digital wealth management, securities custody, deposits, lending and investment-product distribution. The principal Israel-related finding at the platform level is an October 2026 justETF comparison advertising Scalable Capital savings plans for Elbit Systems shares, identified by ISIN IL0010811243. This is security-specific evidence of an advertised recurring-investment facility involving an Israeli defence manufacturer, subject to important execution limits.^{13, 10, 1}

The justETF table displayed a €0 execution fee and €0 account fee for a selected €100 monthly savings amount. Scalable’s own guidance confirms that individual company shares can qualify for savings plans and that savings-plan execution fees are €0 across brokerage pricing models, while other costs can apply. However, the audit did not independently verify an Elbit-specific confirmation from Scalable, completed customer orders, the assigned execution venue or aggregate investment volumes. The €100 comparison setting is not evidence that a customer invested that amount.^{1, 2, 3, 4}

A second economic pathway concerns BlackRock, whose 2025 annual filing identifies Scalable Capital as a minority investment. BlackRock separately completed its acquisition of Kreos Capital in August 2023 and maintains an Israel-facing growth-debt business. Borrower records document post-acquisition financing and restructuring, including BioLineRx’s April 2024 drawdown and subsequent loan modification. These are activities of BlackRock’s acquired lending operation and associated financing vehicles. They do not establish that Scalable owns those loans, controls their allocation or transferred its earnings into them.^{5, 6, 7, 8}

The four audits establish substantial limits. No public evidence identified of Scalable supplying Israeli military equipment, military-purpose software, defence logistics, Israeli state digital infrastructure or settlement-specific financial services. No verified political donation, settlement endorsement, relevant lobbying programme or corporate endorsement of Israeli military operations was identified. Documented global funds and civilian technology services do not independently establish those activities.^{10, 18, 19, 20, 11, 12}

The fixed, human-vetted V6.6 result is BRS 426 - Tier C (Substantial Complicity). Economic supplies the sole non-zero domain score, 5.11; Military, Digital and Political each score 0.00. This dossier preserves that supplied classification while retaining the distinction between advertised brokerage access, shareholder-level economic activity, verified historical transactions and unresolved current exposure.

Timeline of Relevant Events

Corporate Overview

Scalable’s documented corporate identity is European and financial. Its banking entity received ECB authorisation in September 2025 and operates under German supervision. October 2026 corporate disclosures reported more than one million clients, over €60 billion on the platform and more than 800 employees across Munich, Berlin, Vienna and Milan. These are company-wide figures, not measures of Israeli activity.^{10, 27, 15}

The group includes justETF, acquired in 2021, which provides securities information and investment comparisons. Scalable AG is identified as the contracted technical operator of the European Investor Exchange for BÖAG Börsen AG. Scalable Capital Bank GmbH and mwb fairtrade provide market-making liquidity under the documented exchange arrangements.^{11, 21}

UK Companies House identifies Scalable GmbH, Munich registration HRB 215618, as holding at least 75% of Scalable Capital Limited’s shares. The UK company’s proposed voluntary strike-off does not establish dissolution of the German group, an Israeli divestment or an Israel-related enforcement proceeding.^{28, 26}

No public evidence identified of a Scalable-owned Israeli operating subsidiary, Israeli controlling joint venture, Israeli franchise or settlement-based branch. BlackRock’s minority investment must be kept separate from group ownership: BlackRock’s independently managed businesses and client assets do not thereby become Scalable Capital subsidiaries or property.^{13, 5, 6, 7}

Domain Summaries

Military: Military

Mechanism of Involvement

No public evidence identified of Scalable Capital contracting with the Israeli Ministry of Defence, IDF, Israel Prison Service or Israeli Border Police to supply military equipment, weapons, logistics or military-purpose technology. Its documented banking functions are account administration, trading, clearing, settlement, custody, deposits and lending.¹⁰

The military audit also found No public evidence identified of weapons manufacturing, defence-component supply, military freight services, base support or military-specific banking programmes. Its treatment of investment technology remains functional: Agentic Investing supports securities research and customer-authorised account operations; the examined announcement does not describe targeting, weapons control or kinetic military outputs.¹²

The Elbit Systems savings-plan advertisement is an economic brokerage finding. It does not establish a Scalable defence-procurement contract, a payment to Elbit under a military supply agreement or the use of Scalable technology in weapons systems.^{1, 2}

Counter-Arguments and Evidence Limits

The company’s strongest defence is the civilian character of its documented products and the absence of an identified military customer or qualifying supply contract. Financial derivatives and algorithmic investment services do not acquire a military purpose through terminology alone. The reviewed AI announcement describes client authorisation and transaction approval within an investment account.^{10, 12}

Shareholder and commercial-partner relationships cannot substitute for evidence of Scalable’s own military activity. The economic audit documents an advertised Elbit investment facility, but neither customer execution nor resulting flows were verified. It would exceed that evidence to claim that Scalable financed a particular weapons programme or supplied Israeli forces.^{1, 4}

The fixed Military inputs and domain score are all zero. This records the audited evidentiary position; it is not a universal certification that undisclosed relationships cannot exist.

Named Entities and Evidence Map

Digital: Digital

Mechanism of Involvement

Scalable operates financial technology, including brokerage infrastructure and technology supporting the European Investor Exchange. Its privacy disclosures identify AWS hosting, Salesforce customer-service processing and AI functionality involving OpenAI Ireland and AWS. These are documented technology relationships, not evidence of Israeli state or military deployment.^{20, 29, 11}

No public evidence identified of Scalable procuring a specifically identified Israeli-origin cybersecurity platform, supplying technology to Israeli military or intelligence institutions, participating in Project Nimbus, or providing digital infrastructure to an identified settlement operator. The audit likewise identified no verified Israeli research centre or Israeli military AI partnership.^{20, 29, 11, 12}

The Scalable-owned justETF profile of Check Point Software Technologies concerns securities information and a brokerage offer. It does not establish that Scalable procures Check Point cybersecurity products.³⁰

Counter-Arguments and Evidence Limits

The strongest defence is the gap between using general-purpose international technology and supplying or procuring a qualifying Israeli digital system. AWS, Salesforce and OpenAI relationships establish the disclosed processors and functions; they do not establish that Scalable customer data passes through Israeli jurisdiction or supports Israeli state institutions.^{20, 29}

The audit reports No public evidence identified of Israeli data-centre operations or Israeli-jurisdiction processing. That finding should remain limited to the examined disclosures. It does not warrant an exhaustive claim about every subcontractor or infrastructure dependency.

Similarly, stock coverage must not be recast as a vendor contract. Check Point’s appearance on justETF establishes financial-information coverage, while the European Investor Exchange documentation identifies a German exchange counterparty.^{11, 30}

Named Entities and Evidence Map

Economic: Economic

Mechanism of Involvement

The strongest platform-specific evidence is justETF’s October 2026 Elbit Systems listing. It explicitly identified Scalable as offering a securities savings plan for the company’s shares. Scalable’s official eligibility and pricing guidance supports the general mechanism: recurring purchases of eligible individual shares with €0 savings-plan execution fees, subject to spreads and other applicable costs.^{1, 2, 3}

The evidence establishes an advertised facility, not completed purchases or capital raised by Elbit. The comparison does not identify the execution venue, and Scalable’s standard venues are European Investor Exchange, gettex and Xetra. No direct Tel Aviv Stock Exchange operation follows from the listing.^{1, 31}

The second pathway is shareholder-level. BlackRock’s 2025 annual filing confirms a minority investment in Scalable. Historical reporting records a strategic investment and board appointment in 2017; BlackRock’s 2025 investor presentation also identifies Scalable as a private-markets distribution partner. Current ownership percentage, voting rights and continuation of the historical board appointment remain unverified.^{5, 17, 32}

BlackRock separately operates in Israel and acquired Kreos in August 2023. Kreos’s current platform describes growth-debt financing across Europe and Israel. Its more than $7 billion committed and over 830 completed deals, dated Q3 2025, are aggregate business figures and cannot be assigned entirely to Israel.^{6, 7, 33}

Borrower filings provide more precise evidence:

• BioLineRx: $10 million was advanced before BlackRock acquired Kreos, followed by $20 million in April 2024. The final $10 million tranche was never drawn. A November 2024 restructuring included a $16.5 million payment covering partial repayment and cancellation of future revenue-linked payments. The December 2025 carrying balance was approximately $8.939 million, with a repayment schedule extending through December 2027; the exact October 2026 balance remains unverified.⁸
• PolyPid: All $12.5 million of documented advances occurred in 2022. Post-acquisition amendments changed repayment, interest, fees, security and warrant terms, without establishing fresh principal advances. The outstanding loan balance was fully repaid on 4 May 2026; the reviewed repayment disclosure did not resolve every warrant’s subsequent status.^{23, 9, 24}
• Pagaya: A February 2024 disclosure identifies a $280 million facility involving BlackRock-led funds. The figure is facility-wide, not BlackRock’s individually disclosed contribution; current outstanding exposure and subsequent exit remain unresolved.²²

Other findings require narrower treatment. Reporting on BlackRock’s increased Nova holding does not resolve passive versus active mandates or proprietary versus client ownership. Atlas Invest’s Israeli founders do not establish Israeli-domiciled investment because the reported business is Manhattan-based.^{25, 34}

Counter-Arguments and Evidence Limits

Scalable’s strongest defence combines limited agency, separate ownership and unquantified flows. The Elbit evidence is a justETF advertisement consistent with Scalable’s general offering. No independently completed order, customer volume or Elbit-specific account confirmation was verified. The displayed €100 setting must not be treated as an observed investment.^{1, 2, 4}

BlackRock is a minority shareholder, not an established controlling parent. The reviewed evidence does not substantiate the previously cited approximate 29% estimate, current voting control or uninterrupted board representation. Its omission from Scalable’s June 2025 funding participants does not prove divestment, given the subsequent annual-filing disclosure.^{16, 5, 17}

BlackRock’s lending operations, fund investments and client portfolios remain separately attributable. No public evidence identified of a quantified Scalable dividend to BlackRock, an earmarked transfer into Israeli lending or Scalable ownership of Kreos loans. A potential shareholder economic-benefit pathway is distinguishable from a verified onward payment.^{16, 5, 6, 7}

Temporal mitigation is material. PolyPid’s repaid principal cannot be described as continuing October 2026 debt exposure. BioLineRx’s December 2025 accounting balance cannot be presented as the precise current principal. Pagaya’s unresolved present status supports a documented historical transaction, not an asserted current balance.^{8, 9, 22}

Finally, Scalable’s global ETF advisory role does not establish a quantified Israeli allocation. No public evidence identified of direct Israeli sovereign underwriting, a named settlement loan or a Scalable-owned Israeli operating acquisition. Its €60 billion platform figure is not Israel-specific exposure.^{13, 18, 27}

Named Entities and Evidence Map

Political: Political

Mechanism of Involvement

No public evidence identified of a Scalable corporate statement endorsing Israeli military operations, advocating settlement expansion or Palestinian displacement, or announcing a relevant political donation or lobbying programme. The reviewed communications describe European investment access, banking authorisation, funding and product development.^{13, 10, 16, 12}

The political audit likewise found No public evidence identified of settlement sponsorship, military-welfare matching, conflict-related employee sanctions or executive-directed political expenditure on Scalable’s behalf. Its documented BlackRock and DWS relationships establish investment and distribution roles, not a political-financing programme.^{17, 18, 19}

Counter-Arguments and Evidence Limits

The strongest defence is the absence of verified political conduct. Commercial continuity after July and November 2024 does not independently establish continued political or military support. Neither global fund participation nor an executive’s financial-services career proves endorsement of Israeli government policy.^{10, 16, 18, 12}

The audit identified neither a Palestine-specific corporate humanitarian response nor a verified comparative geopolitical statement sufficient to establish inconsistent treatment. Silence should not be converted into affirmative support.

The fixed Political input I=2.00 is retained as instructed. No separate reviewed rationale was supplied that would justify attributing a specific political act to that input. With M=0.00 and P=0.00, the supplied domain result remains 0.00.

Named Entities and Evidence Map

Complicity Index Score

Method: V6.6. Final human-vetted values are reproduced without alteration.

• V_MAX: 5.11 Avg_OTHERS: 0.00
• BRS Score: 426 Tier: C (Substantial Complicity)

Economic supplies V_MAX: the audited economic record combines the advertised Elbit savings-plan facility with BlackRock’s documented minority investment and separately attributable Israel-facing economic activities, subject to the execution, ownership and temporal limits above.^{5, 1, 6, 8, 9} The resulting 426 / Tier C classification is the supplied vetted outcome; no unpublished numerical allocation between those findings is inferred. The method is scale-free, evidence-only and human-vetted: activity type, scale and directness remain distinct, and transaction size alone does not resolve agency or attribution.

Methodology Note

• This dossier compiles the four supplied domain audits, with an evidence cut-off of 25 October 2026. It introduces no independently researched allegations.
• Impact (I) concerns activity type on a scale-free basis; Magnitude (M) concerns scale; Proximity (P) concerns directness. Company-wide assets, aggregate multinational commitments and facility-wide amounts are not interchangeable with attributable Israeli exposure.
• The temporal rule mitigates divested, exited or repaid activity. PolyPid’s May 2026 repayment is incorporated; unresolved warrant status is not treated as continuing principal debt.^{23, 9}
• Entity attribution excludes transitive guilt. Minority-shareholder businesses, managed client assets, fund-manager responsibilities and Scalable’s own activities remain distinct.^{5, 18, 19}
• Verified settlement operations would count in both Economic and Political. No such Scalable operation was established in the supplied audits; general financial-product relationships do not establish one.^{18, 11}
• “No public evidence identified” reports a negative audit finding, not proof of universal absence. Unverified execution, ownership percentages, current balances and investment mandates remain expressly unresolved.