Vanguard Direct Indexing fees and minimums: what Vanguard Personalized Indexing actually costs.
Every review says Vanguard does not publish its direct indexing pricing. Vanguard does publish it, in a filing almost nobody opens. Here is the full tiered fee schedule, all three minimums, and what the client list says about whether you can buy it at all.
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In short
Vanguard direct indexing is sold as Vanguard Personalized Indexing, run by Vanguard Personalized Indexing Management, LLC, the Oakland firm Vanguard acquired as Just Invest in 2021. Its Form ADV Part 2A, dated July 22, 2026, prices it at 0.20% a year in the first tier when an adviser places the account, stepping down to 0.18% and 0.15% as that adviser's book grows, with a preferred minimum account size of $250,000. Going direct to Vanguard is more expensive, not less: that schedule starts at 0.27% and carries a $10,000,000 minimum. Index licensing fees of 0.010% to 0.0275% can apply on top, and so does your own adviser's fee. As of the same filing, VPIM managed $11.35 billion across 4,085 accounts, of which 99.4% belonged to 203 other investment advisers and exactly one client was an individual.
Last updated August 2026
Vanguard direct indexing fees
Vanguard does publish its direct indexing fee. It is just not on vanguard.com
The public product page at advisors.vanguard.com carries no pricing at all. It does not have to. A registered investment adviser does have to file a fee schedule with the SEC, and Vanguard Personalized Indexing Management, LLC is a registered investment adviser in its own right, CRD number 285366. Here is what it filed on July 22, 2026.
Table one: priced on your adviser's total book, not your account
This is the schedule that applies to almost everyone, because almost everyone reaches the product through an RIA or a wealth manager. Note what the left column measures. It is not your money. It is the aggregate that your adviser has placed with VPIM across every client they have.
| Adviser aggregate assets under management | Annual fee rate |
|---|---|
| $250,000 to $50,000,000 | 0.20% |
| $50,000,001 to $100,000,000 | 0.18% |
| $100,000,001 to $500,000,000 | 0.15% |
| $500,000,001 and over | Custom |
That structure has a consequence worth understanding before you shop. Your rate depends on how much business your adviser already does with Vanguard, which is a fact about them, not about you. Two clients with identical $400,000 accounts at two different firms can be paying 0.20% and 0.15% for the same service.
Table two: priced on your own account, if it is large enough
| Individual account assets under management | Annual fee rate |
|---|---|
| $10,000,000 to $50,000,000 | 0.15% |
| $50,000,001 to $100,000,000 | 0.13% |
| $100,000,001 and over | Custom |
The two tables are not alternatives you choose between. The brochure says accounts "will be assessed the lower available rate between the two above tables, where possible and as applicable", and then works through its own example: an adviser with $15,000,000 at VPIM, of which $10,000,000 sits in one client account, sees that account priced at 0.15% and the remaining $5,000,000 priced at 0.20%.
Two more line items belong in any honest total. The first: "additional index licensing fees ranging from .010% to .0275% will be charged" where an end client selects investment universes from certain index providers, outside TAMP and wrap programs. The second is open ended, and worth asking about directly: "custom data requirements, asset location services, and multi-account tax coordination may incur additional fees that will be enumerated in the investment management contract."
Vanguard direct indexing for individuals
Going direct to Vanguard costs more than going through an adviser
VPIM does take a small number of clients directly. The schedule for them is separate, and it runs the wrong way against every instinct about cutting out the middleman.
| Direct client portfolio assets | Annual fee rate |
|---|---|
| $10 million to $15 million | 0.27% |
| $15 million to $25 million | 0.22% |
| $25 million to $50 million | 0.17% |
| $50 million to $100 million | 0.12% |
| Over $100 million | Custom fee rate |
Read the first row against the first row of the sub-advisory table. Direct, you pay 0.27% and you need $10 million. Through an adviser, you pay 0.20% and you need $250,000. The direct route is 35% more expensive per dollar and demands forty times the assets, and the brochure attaches the minimum to it in plain language: "There is an account minimum of $10,000,000, which may be waived by VPIM in its discretion."
This is not irrational on Vanguard's part. A direct client needs an investment policy statement written for them, service delivered to them, and a relationship maintained with them, all work an RIA would otherwise absorb. The premium is the price of that work. But it does dispose of the idea that there is a cheaper back door if you are willing to skip the adviser. There is a door, it is expensive, and it opens at eight figures.
One caveat in the other direction. Skipping the adviser does remove the adviser's own fee, and in most real portfolios that fee is much larger than anything on this page. An adviser charging 1% a year on top of a 0.20% strategy fee accounts for roughly five sixths of what you pay. Whether that is money well spent is a genuine question, but it is a question about the adviser, not about Vanguard.
Vanguard personalized indexing minimum
There is no single Vanguard Personalized Indexing minimum. There are three
The $250,000 figure that circulates in reviews and forum threads is real, but it is one of three, and it is the smallest. Which one applies to you is decided by how the account reaches VPIM.
$250,000
Preferred minimum account size
The standard route: your RIA or wealth manager places the mandate with VPIM as sub-adviser.
$1,000,000
Through a Turnkey Asset Management Program
Verbatim: "Clients introduced to VPIM through a Turnkey Asset Management Program, have a higher minimum account size of $1,000,000."
$10,000,000
Direct client of VPIM
Verbatim: "There is an account minimum of $10,000,000, which may be waived by VPIM in its discretion."
Note the word "preferred" on the first one. The brochure adds that VPIM "reserve[s] the right to provide services at smaller account sizes at our discretion", so $250,000 is a policy rather than a hard gate. Wrap programs are looser again: "VPIM requires a minimum account size for certain of its investment strategies, which varies among Wrap Programs", with the sponsor setting the terms. If a specific number matters to your decision, get it in writing from whoever is quoting it.
Can retail investors buy it
The retail channel for Vanguard direct indexing is one person
Form ADV Part 1A asks every adviser to break its assets down by client type. VPIM's answer, filed July 22, 2026, settles the "is it really adviser only" question more decisively than any marketing page could.
| Type of client | Number of clients | Regulatory assets under management | Share of total |
|---|---|---|---|
| Other investment advisers | 203 | $11,286,791,050 | 99.4% |
| Corporations or other businesses | 1 | $65,724,154 | 0.6% |
| High net worth individuals | 1 | $2,181,914 | Under 0.1% |
| Individuals (other than high net worth) | 0 | $0 | 0% |
| Pooled investment vehicles | 0 | $0 | 0% |
| Pension and profit sharing plans | 0 | $0 | 0% |
Two hundred and three investment advisers hold 99.4% of the assets. One high net worth individual holds $2,181,914. One business holds $65,724,154. There are zero pooled vehicles, zero pension plans, zero ordinary individuals. Total regulatory assets under management are $11,354,697,118 across 4,085 accounts, an average of about $2.78 million per account, all of it discretionary, and none of it attributable to non-United States persons.
So when a review tells you Vanguard Personalized Indexing has a $250,000 minimum, the sentence is true and the implication is misleading. It is not a $250,000 product you can sign up for. It is a wholesale product bought by advisers on behalf of their clients, and the $250,000 is the size at which an adviser will bother placing one. If you do not have an adviser, the practical minimum is the $10,000,000 direct schedule. If you are comparing against something you could actually open this afternoon, you want the direct indexing platforms individuals can open directly.
Vanguard direct indexing vs alternatives
How the filed Vanguard pricing compares to everyone else
| Provider | Minimum | Annual fee | Index choice | How you buy it |
|---|---|---|---|---|
| Vanguard Personalized Indexing | $250,000 via an adviser, $10,000,000 direct | 0.20% adviser tier 1, 0.27% direct tier 1, plus your adviser fee | Custom, adviser configured | Adviser only |
| Parametric Custom Core (Domestic Equity) | $250,000 direct, $25,000 via Select UMA | 35 bps manager fee, plus platform fees | Any standard or custom benchmark | Adviser only |
| Schwab Personalized Indexing | $100,000 | 0.40%, 0.35% above $2M | 6 strategies, no S&P 500 option | Direct to retail |
| Fidelity Managed FidFolios | $5,000 to be invested | 0.40% index, 0.70% active | 8 strategies | Direct to retail |
| Wealthfront S&P 500 Direct | $5,000 | 0.09% | S&P 500 | Direct to retail |
| Frec Classic | $20,000 to $50,000 | 0.09% to 0.35% | 25 indices | Direct to retail |
| S&P 500 index ETF | 1 share | 0.03% to 0.10% | One fund | Any brokerage |
Taken at face value, 0.20% looks strong. It undercuts Schwab Personalized Indexing at 0.40% and Fidelity Managed FidFolios at 0.40% for their index strategies, and it sits below Parametric Custom Core's 35 bps. That comparison is only fair, though, if you compare the same layer of the stack.
Schwab, Fidelity, Wealthfront and Frec quote a rate you can pay. Vanguard and Parametric quote a manager fee that arrives with an adviser attached. Add a typical 1% advisory fee to Vanguard's 0.20% and the all-in number lands near 1.2%, which is not competitive with Wealthfront's 0.09% or Frec's 0.09% to 0.35%, and is roughly forty times an S&P 500 ETF. Whether that is worth paying turns entirely on what the adviser does for you beyond running the index, and on whether you have enough realized gains for the harvesting to bite.
Vanguard direct indexing tax loss harvesting
What the product actually does, in the filing's own words
The harvesting here is algorithmic, which is a meaningful difference from some competitors. The brochure names two systems: a Rebalancing Algorithm that "identifies portfolio rebalancing opportunities and initiates buy/sell orders to maintain applicable portfolio requirements, model weights, and/or index tracking", and a Tax Loss Harvesting Algorithm that "identifies tax-loss harvesting opportunities and initiates buy/sell orders to harvest such tax losses in taxable accounts". Compare that to Fidelity, which describes harvesting as applied "on a limited basis, at the discretion of the portfolio manager", or Parametric, which harvests "when deemed, in Parametric's discretion, to be in the client's best interest".
Wash sales get an explicit mention, and the phrasing is unusually candid about tracking error. Where VPIM follows a model portfolio it says it "may substitute or otherwise deviate from the Model as it deems appropriate", and gives the reasons: "to comply with individual client guidelines or restrictions, to realize losses in taxable accounts, or to provide market exposure during a wash sale period". That last clause describes buying a stand-in during the 61-day window so the portfolio stays invested while a loss is preserved. It is the correct mechanic, and it is also why your account will not match the index exactly.
What no manager can solve for you is the account it cannot see. If a 401(k) contribution or an automatic purchase in another brokerage buys a substantially identical security inside that 61-day window, the loss is disallowed under IRC 1091 no matter how carefully VPIM traded. Where the replacement shares land inside an IRA, IRS Revenue Ruling 2008-5 makes it permanent: the loss is gone and your IRA basis is not increased. Schwab discloses this limitation directly for its own product. It applies to every provider in the category.
On what the harvesting is worth, keep expectations anchored to published research rather than sales decks. Providers across this category commonly market 1% to 2% of annual after-tax alpha. Wealthfront's own whitepaper, backtesting February 2015 through December 2025, reports a harvesting yield advantage of 1.01% over an ETF-only portfolio, which converts to 0.18% to 0.44% a year of account value at marginal rates between 18% and 44%. A harvested loss is only worth something if you have realized gains to offset, or can use the $3,000 a year ($1,500 if married filing separately) that nets against ordinary income under IRS Topic 409. Our direct indexing tax loss harvesting guide works through the arithmetic.
Two eligibility rules are worth knowing before anyone spends time on a proposal. Company insiders are excluded outright: officers, directors and substantial shareholders "including any employees subject to Rule 144 of the Securities Act of 1933" or "Section 16 of the Securities Exchange Act of 1934" are not eligible. And clients "are generally required to maintain permanent residence in one of the of 50 states, the District of Columbia, or the U.S. Virgin Islands", with a narrow carve-out for military and government personnel temporarily abroad.
Questions people ask
Vanguard direct indexing questions, answered
Does Vanguard offer direct indexing?
Yes, through a subsidiary called Vanguard Personalized Indexing Management, LLC, which Vanguard created by acquiring Just Invest in 2021. It runs direct indexing as a separately managed account or inside a unified managed account, holding the individual stocks that track an index you choose. What it does not do is sell to the public. Its own Form ADV describes it as serving RIA firms and wealth managers "primarily as subadviser", and its client list bears that out.
How much does Vanguard direct indexing cost?
Through an adviser, the standard schedule starts at 0.20% a year and steps down to 0.18%, 0.15% and then a custom rate as the adviser's aggregate book with VPIM grows. A parallel table prices large individual accounts at 0.15% from $10 million, and accounts get the lower of the two rates. Direct clients pay a different and higher schedule that starts at 0.27%. All of it sits in Vanguard Personalized Indexing Management's Form ADV Part 2A dated July 22, 2026.
What is the minimum for Vanguard Personalized Indexing?
There are three. The brochure states that "VPIM's preferred minimum account size is $250,000", that clients introduced through a Turnkey Asset Management Program "have a higher minimum account size of $1,000,000", and that direct clients face "an account minimum of $10,000,000, which may be waived by VPIM in its discretion." The $250,000 figure that circulates online is the first of those three, and it only applies when an adviser places the account.
Can I get Vanguard direct indexing as an individual investor?
Not in any practical sense. There is no Vanguard Personalized Indexing login you can open from a normal Vanguard brokerage account, and the direct channel carries a $10,000,000 minimum. The scale of this is visible in the firm's own Form ADV Part 1A filed July 22, 2026: of $11.35 billion under management across 4,085 accounts, exactly one client is a high net worth individual, holding $2,181,914. Everything else runs through other advisers.
Is it cheaper to go direct to Vanguard instead of through an adviser?
No, and this surprises people. The Direct Client schedule starts at 0.27% for portfolios between $10 million and $15 million, while the sub-advisory schedule starts at 0.20% at $250,000. So the direct route costs more per dollar and demands forty times the assets. Cutting out the adviser does remove the adviser's own fee, which is the larger number in most cases, but it does not get you a better rate from Vanguard.
What is Vanguard Personalized Indexing Management, LLC?
It is the SEC-registered investment adviser that runs the product, CRD number 285366, based at 1611 Telegraph Ave in Oakland, California. It is "an indirect wholly owned subsidiary of The Vanguard Group, Inc." and was previously named JustInvest, LLC, the business Vanguard acquired in 2021. It files its own Form ADV, which is why its pricing is public even though vanguard.com does not display it.
Are there extra fees on top of the Vanguard direct indexing fee?
Yes, several. The brochure discloses "additional index licensing fees ranging from .010% to .0275%" for accounts selecting certain index providers, outside TAMP and wrap programs. It also notes that "custom data requirements, asset location services, and multi-account tax coordination may incur additional fees". Separately, clients pay custodian and brokerage charges, and in the normal case your own adviser's fee sits on top of all of it.
Does Vanguard Personalized Indexing do tax loss harvesting?
Yes, and it is automated rather than discretionary. The brochure names two algorithms: a Rebalancing Algorithm that "identifies portfolio rebalancing opportunities and initiates buy/sell orders", and a Tax Loss Harvesting Algorithm that "identifies tax-loss harvesting opportunities and initiates buy/sell orders to harvest such tax losses in taxable accounts". It also describes deviating from a model "to realize losses in taxable accounts, or to provide market exposure during a wash sale period".
Is the Vanguard direct indexing fee negotiable?
Yes, explicitly, and in both directions. The brochure states that "VPIM may negotiate lower fees depending on the nature of the strategy, account size, and overall relationship" and that it "reserves the right to negotiate fees that may be more or less advantageous than those charged to other Clients for similar services." For sub-advisory work it also notes that "fees are negotiated with the primary RIA or wealth manager of the end Client, not directly with the end Client", so the rate is settled above your head.
What indexes can Vanguard Personalized Indexing track?
The brochure does not publish a fixed menu the way the retail platforms do. It describes "broad market exposure", asset allocation across geographies and risk factors such as growth versus value, an Active Equity approach using investment signals, and optional SRI and ESG screens applied "in conjunction with Client-selected preferences". Certain index universes carry the extra licensing fee noted above, which implies third-party index families are available on request rather than from a list.
Who is not eligible for Vanguard Personalized Indexing?
Two groups, named directly in the brochure. Company insiders are excluded: "Certain officers, directors, and substantial shareholders, including any employees subject to Rule 144 of the Securities Act of 1933, as amended, or Section 16 of the Securities Exchange Act of 1934, as amended, are not eligible for VPIM advisory services." So are most people abroad, since clients "are generally required to maintain permanent residence in one of the of 50 states, the District of Columbia, or the U.S. Virgin Islands."
How much does Vanguard Personalized Indexing manage?
Its Form ADV Part 1A filed July 22, 2026 reports $11,354,697,118 in regulatory assets under management across 4,085 accounts, all of it discretionary and none of it attributable to non-United States persons. That averages about $2.78 million per account. For scale, Parametric, the largest manager in the category, reported roughly $684.7 billion as of December 31, 2025.
Is Vanguard direct indexing worth it compared to an S&P 500 ETF?
Only if you will actually use the tax management. A Vanguard S&P 500 ETF costs 0.03% and needs one share. Direct indexing here costs at least 0.20%, plus index licensing, plus your adviser, so you are paying perhaps 1.2% all in against 0.03%. That gap has to be earned back by harvested losses you can genuinely use against realized gains. Published research puts the benefit far below the marketing: Wealthfront's own whitepaper reports 0.18% to 0.44% a year of account value, not the 1% to 2% commonly advertised.
What happened to Just Invest after Vanguard bought it?
It became Vanguard Personalized Indexing Management, LLC. The SEC record still lists "JUSTINVEST, LLC", "JUST INVEST" and "JUST INVEST ADVISORS LLC" among the firm's former names under the same CRD number, 285366, and the firm still operates from Oakland rather than Vanguard's Malvern headquarters. Vanguard announced the acquisition in 2021 and folded the technology in as its direct indexing offering for advisers.
Sources
Fee schedules, account minimums, index licensing fees, algorithms, eligibility restrictions and strategy descriptions: Vanguard Personalized Indexing Management, LLC, Form ADV Part 2A firm brochure, version dated 7/22/2026, Items 4, 5, 7 and 8. Assets under management, account counts and the client type breakdown: the same firm's Form ADV Part 1A, executed 07/22/2026, Items 5.D and 5.F. Both retrieved from the SEC's Investment Adviser Public Disclosure system under CRD number 285366. Product description: advisors.vanguard.com Personalized Indexing page. Competitor fees and minimums re-verified from each provider's own pricing page or filing, dated in our published notes. Tax figures: IRS Topic 409, IRC 1091, IRS Revenue Ruling 2008-5, and the Wealthfront tax loss harvesting whitepaper. Indexes is not affiliated with, endorsed by or sponsored by The Vanguard Group or Vanguard Personalized Indexing Management, LLC. We are index construction and backtesting software: we do not manage money, place trades, custody assets or provide tax advice.
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