Investing30 July 2026· Updated 29 July 2026· 11 min read

C3M money-market ETF: real government bills for parking cash

The founder of Rebalix
C3M money-market ETF: real government bills for parking cash

In our first money-market piece we covered Xeon, which «becomes» the overnight rate via a swap. C3M gets there by the opposite road: it buys real government bills, at very short maturities, rolling them every week. Same category, opposite philosophy — with measurable differences in costs, taxes and risks. We measure them all, over nine years of data.

First things first
This is an educational article, not advice: we are not telling you to buy, sell or hold C3M, Xeon or anything else. It exists to explain how a physically replicated money-market ETF works and how it compares with a synthetic one.

1. What a money-market ETF is (60-second recap)

A money-market ETF is a tool for «parking» cash: it follows the euro’s very short-term interest rates. When ECB rates rise it earns more; when they fall — or go below zero, as they did from 2015 to mid-2022 — it earns little or slowly loses. It is not a deposit account: it is an exchange-traded fund whose price moves every day — very little, but it moves. The full recap, with a yield calculator, is in our Xeon article.

2. What they are for, according to research

Academic finance has a name for very short government paper: near-money. Stefan Nagel (Quarterly Journal of Economics, 2016) measured the premium the market pays for assets liquid enough to be almost cash: holders accept a slightly lower yield in exchange for the ability to exit at any time. Krishnamurthy and Vissing-Jørgensen (Journal of Political Economy, 2012) showed investors consistently pay up for the safety and liquidity of government debt. Translated from the academic: these instruments exist to store money that must stay available — not to grow it. European law says the same: EU Regulation 2017/1131 defines money-market funds as tools for «short-term liquidity management». Using them for long-term goals is a category error — true of C3M, Xeon and any money-market fund.

3. The identity card

ItemValue
NameAmundi Euro Government Bond 0-6 M UCITS ETF Acc
ISINFR0010754200
Tickerdepends on the exchange — see venues below
TER (management)0.14% — but see the costs section
Assets (AUM)€0.93bn
ReplicationPhysical (actually owns the bills)
Securities lendingNone (per prospectus)
DistributionAccumulating
IndexFTSE Eurozone Government Bill 0-6 Month Capped
Launch22 June 2009 (French FCP)
Risk (SRRI)1 of 7
Listed onEuronext Paris · C3MBorsa Italiana · C3MXetra (Francoforte) · C3MGR
Authorised for sale inFinlandFranceGermanyItalyNetherlandsSwitzerland(institutional only)United Kingdom
Where it shows up commission-free in Italy

According to the official lists published by the brokers (downloaded and cross-checked by us), these share classes of the fund appear tradable with zero fees:

FR0010754200C3M
  • Directazero within the savings plan (buys)
  • Finecozero on buys (single orders and savings plan) — promo list renewed monthly: check it is still listed
  • Moneyfarmzero within the savings plan (buys), agreement until 15 May 2027
  • Moneyfarmzero on single buys from 1,000 €, agreement until 15 May 2027
  • XTBzero (up to €100,000 monthly volume, unreachable for a retail plan); fractions available in plans
Full terms, traps and method in the observatory: Free savings plans and zero-commission ETFs: the broker survey

Official lists verified on 23 July 2026. We record published terms — this is neither an invitation to open accounts nor a recommendation: lists change, the broker’s documents prevail. Trade Republic, Scalable Capital and Trading 212 publish no per-ISIN lists and don’t appear here.

Two rows are worth the whole article. Physical replication: C3M owns the bills, not a contract promising their return — the exact opposite of Xeon (the trade-offs of each route are explained in Physical or synthetic replication). And securities lending: none — we verified it in the prospectus («transactions involving the temporary acquisition and/or disposal of securities: none», April 2026 edition): no extra lending income, but also zero counterparty risk from that door. Live data source (NAV, assets, authorisations): Amundi’s official API, refreshed daily.

A distinction that trips up even seasoned investors: authorised does not mean listed. The fund is authorised for sale in 7 countries (the UCITS «passport»: regulatory permission to offer it to that country’s investors) but listed on just 3 exchanges — Xetra, Paris and Milan. A Finnish or Dutch investor simply buys it on one of those venues through their broker: no home listing needed. Switzerland is the special case: authorised, yes, but for institutional investors only — Swiss retail cannot buy it.

4. Inside the basket: the «T-bills» of 7 countries

The index buys bills — discount Treasury paper — issued by 7 eurozone states: France, Germany, Spain, Italy, Belgium, the Netherlands and Portugal, each with at least two short-term investment-grade ratings. Maturities under 6 months. The «Capped» in the name is a ceiling: no issuer above 34.5% — without it, France and Italy (the largest bill issuers) would dominate. Amundi publishes the complete basket daily — 55 instruments today, each with ISIN and weight, downloadable from the fund page — and we archive it every day: its changes over time will become part of this page. Here, for readability, the country mix and the top 10 holdings:

CountryWeight
France34.17%
Italy21.13%
Germany16.06%
Spain12.08%
Belgium8.61%
Netherlands6.41%
Portugal1.55%

The technical detail that explains half the article: the index rebalances weekly (bills mature constantly and must be replaced). A physical fund tracking it must therefore trade every week. Keep that in mind: it returns in the costs section. Source: the index’s official ground rules (FTSE Russell, v3.3, May 2026 — public document).

5. Performance — and the true cost of tracking

How it has performed — fund and index, since 2017
Cumulative return since 10 July 2017 (start of the issuer’s rebased index series), computed on the official Amundi NAV. Blue is the fund, amber its index: the gap between the two is the true cost of replication — measured year by year in the table below.
-4%-2%0%+2%+4%+6%+8%2017201820192020202120222023202420252026
C3M (fund)
+6.19%
Cumulative
Index
+7.63%
Cumulative
Annualised
+0.67%
C3M (fund) · 9y
Data as of 24 Jul 2026. Official Amundi NAV and index as republished by the issuer; calendar-year returns match Amundi’s declared figures (automatic check at every update). One point per month in the chart; computations use daily data. Gross of taxes. Past performance is not indicative of future results.
The true cost: three numbers that don’t match
The TER is the declared «list price». The KID adds estimated transaction costs (the fund rolls bills every week, by index construction). But the cost you ACTUALLY paid is the measured fund–index gap: the tracking. Below, year by year.
TER (management)
0.14%
KID: total estimated cost
0.25%
Measured drag (tracking, 9 years)
0.15%
Why is the measured figure below the estimate? Part of the roll cost is already inside the index: under FTSE rules new bills enter the index at the bid-offer price a replicating fund actually pays — the benchmark «pays» that toll too, so it vanishes in the difference. The rest is the prudence of standardised PRIIPs estimates on Europe’s most liquid instruments.
YearFundIndexTD
2018−0.72%−0.51%-21 bp
2019−0.58%−0.38%-20 bp
2020−0.60%−0.47%-14 bp
2021−0.75%−0.64%-11 bp
2022−0.46%−0.29%-17 bp
2023+2.89%+2.99%-11 bp
2024+3.53%+3.65%-12 bp
2025+2.09%+2.23%-14 bp
2026 · partial+1.10%+1.16%-6 bp
Whole period (annualised)+0.67%+0.82%-15 bp
Tracking difference = fund return − index return, per calendar year, on the official NAV. Returns match Amundi’s declared figures (automatic check at every update, 0.05-point tolerance). Data as of 24 Jul 2026.

The takeaway: the KID declares ~0.25% a year in total costs (0.14 management + 0.11 estimated transactions), yet the measured fund–index gap is 15 basis points a year over 9 years — essentially the TER alone. Nobody is wrong: that is the difference between a prudent regulatory estimate and a measurement. It is also why, when comparing funds, we look at measured tracking rather than sums of declared costs.

6. Drawdown: what «losing» means for a money-market fund

Drawdown: the long (slow) descent of negative rates
This is not the return: it shows how far the fund sits below its previous peak. 0% = at the peak; below zero = ground still to recover. You won’t see crashes here: you’ll see a few points lost over years — the effect of below-zero rates (2015–2022) on the whole money-market category, not a flaw of this fund.
0%-1%-2%-3%-4%20172019202120232025−3.63% · Sept 2022
Max drawdown
−3.63%
Trough
Sept 2022
Longest underwater
80 months
Recovered
yes
Our computation on the official Amundi NAV, data as of 24 Jul 2026. Gross of taxes. Past results are not indicative of future ones.

Read the number for what it is: a 3.63% maximum drawdown in 9 years, built not in a crash but in a slow, years-long descent — the negative-rate era, when the whole euro money-market category lost a few tenths of a point per year by construction. It is not a C3M flaw (Xeon lived the same story): it is what happens to any cash-parking vehicle when the reference rate sits below zero. Inflation is a separate matter — it hits deposits, money funds and idle cash alike — and it lives in the «net of inflation» toggle above.

7. Taxes: where physical changes the game

The true tax rate on gains, today
For Italian-taxed investors, a 98.9% «white list» government-bond basket means a 12.64% effective rate on gains — close to the 12.5% theoretical floor. Xeon, synthetic, derives its share from the swap collateral: lower today, and above all moving.
Every six months issuers report to banks and brokers the share of the fund invested in Italian and «white list» government bonds: that share is taxed at 12.5% instead of 26% (Ministerial Decree 13/12/2011; Revenue Agency Circular 11/E/2012). The effective rate is the weighted average of the two: 12.5% × share + 26% × (1 − share). What matters is the share of the semester in which you sell, not the one when you bought.
C3M
white-list share 98.9%
12.64%
XEON
white-list share 78.1%
15.46%
Always double-check the share with your broker: the instrument page shows it and their document prevails. This is an informational simplification (it ignores stamp duty and individual situations), not tax advice.
Source: issuers’ official tax documents, July 2026 – December 2026 semester. Verified on 28 Jul 2026.
Pages in our white-list database: C3M · XEON
What you keep if you sell — it depends on WHEN
Same investment in both since 31/12/2024. Each group of bars is a sale date: the solid part is the gain you keep, the faded part is the tax — computed with the white-list rate of THAT sale’s semester, from the issuers’ official documents. C3M’s rate stands still (~12.6-12.7%); XEON’s moves with the swap collateral, and in 2026 it rose sharply.
C3MXEONnet % (gross = full bar · rate below)
+1.02
+1.07
30 Jun 2025
12.6% · 13.3%
+1.83
+1.93
31 Dec 2025
12.7% · 13.4%
+2.67
+2.77
30 Jun 2026
12.7% · 14.2%
+2.82
+2.87
today
12.6% · 15.5%
We record the past, we don’t suggest when to sell: next semester’s rate is not predictable. Gross returns from official NAVs (base 31/12/2024, data as of 27 Jul 2026); rates = 12.5%·share + 26%·(1−share) using the issuer document valid on the sale date. Stamp duty and prior losses excluded: always check with your broker. Not tax advice.

This chart is why we keep a semester-by-semester archive of white-list documents: Xeon’s rate has swung between 12.87% and 15.46% across 11 semesters — the same gain sold in different semesters paid different taxes, discovered only at the moment of sale. C3M, by contrast, is fiscally predictable: physically holding government bills pins the share at 98-99%. A virtue no factsheet mentions.

8. C3M vs Xeon: head to head

YearC3MXEONgap
2018−0.72%−0.48%−24 bp
2019−0.58%−0.50%−8 bp
2020−0.60%−0.57%−3 bp
2021−0.75%−0.59%−16 bp
2022−0.46%−0.03%−43 bp
2023+2.89%+3.27%−38 bp
2024+3.53%+3.79%−26 bp
2025+2.09%+2.23%−14 bp
2026 (partial)+1.10%+1.08%+2 bp

Gross returns say: Xeon ahead, but with a narrowing gap — from +43 basis points in 2022 to +14 in 2025. Two structural reasons. First: Xeon’s index embeds a +8.5bp annual premium over €STR. Second: the two curves react to rate cycles at different speeds — the overnight adjusts instantly, 0-6 month bills price ECB moves in advance. In 2022, amid rapid hikes, overnight was the place to be; as the cycle normalises the gap shrinks. On measured costs: Xeon loses ~10bp a year to its index, C3M ~15 — a few basis points apart, not the 15 the KIDs would suggest. Net of taxes the distance narrows further, as the «what you keep» chart showed, where the sale-semester rate does the work. No verdict, then — two instruments of the same category with different profiles: minimal cost and reactivity (Xeon) versus simplicity, real ownership and tax predictability (C3M).

9. Official documents

10. In short

Disclaimer
Informational and educational content, not financial or tax advice. Live data (prices, assets, composition, white-list shares) refresh automatically from the official sources cited; past performance is not indicative of future results. Before any decision, read the KID and prospectus and consider your own situation, with an independent adviser if needed.
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Author
The founder of Rebalix
Founder of Rebalix — on Finanzaonline, Italy's main finance forum, he posts as “Linusale”, a long-time contributor to the ETF and LifeStrategy threads. He spent decades in banking — from traditional banks to senior roles at firms specialised in wealth management, corporate and investment banking. After seeing how finance works from the inside, he built Rebalix to bring that same rigour to the side of the self-directed investor: explaining in plain words how a portfolio actually works — method, costs and discipline — without jargon or easy promises. He does not provide financial advice: the content is for informational and educational purposes.
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