Vanguard’s advice services charge you advisory fees, not commissions, but they don’t fit the strict meaning of fee-only. They recommend Vanguard’s own funds, whose expense ratios are revenue to The Vanguard Group, and they require a Vanguard brokerage account, run by an affiliate that earns from bank sweeps and some outside funds. On $1 million, Vanguard Personal Advisor’s expected net fee is about $3,100 a year, against a median $4,500 for a flat-fee planner.
Fee-only means you are the only one paying: no commissions and no other payments tied to the products you’re advised to buy, to the firm or its related companies. Vanguard’s own filings explain where its affiliates earn money, and two of its services are built to hand part of it back.
How Vanguard’s advice is paid
The advice comes from Vanguard Advisers, Inc. (VAI, CRD 106715), an SEC-registered investment adviser owned by The Vanguard Group. Its Form ADV Part 1, filed October 22, 2026, reports pay as a percentage of assets and fixed fees (Item 5E). Commissions aren’t checked. Under other business (Item 6A), VAI isn’t a broker-dealer or an insurance agent.
Item 7A reports a related broker-dealer, a related insurance company or agency, trust companies and other advisers. The related persons it lists include Vanguard Marketing Corporation (the broker, CRD 7452), Vanguard Fiduciary Trust Company, Vanguard National Trust Company and VGI Insurance, Inc. The advice brochures don’t describe any insurance or annuity sales, and the Form CRS says lead recommendations generally won’t include annuities.
The Form CRS (August 20, 2026) is direct about the funds: “Our lead advice will be to invest in Vanguard funds.” You pay the funds’ expense ratios, which “are received by The Vanguard Group, Inc., an affiliate, as revenue.”
On the people, the CRS says advisors “are not compensated for, or on the basis of, any recommendation or sales of specific securities.” They get base pay and a company-wide annual payment. Some can also earn variable pay, and the brochures list what it’s measured on: client enrollments, retention, consultations and, at times, assets clients bring in. VAI says some of these factors give advisors “an incentive to recommend advisory programs over other services offered by Vanguard.”
What else the filings disclose
The fund credit. Digital Advisor and Personal Advisor charge a gross fee, then subtract the revenue Vanguard keeps from the funds in your account. The brochure (September 24, 2026) says the credit covers expense ratios of Vanguard funds and other Vanguard revenue such as 12b-1 or revenue sharing fees. It isn’t applied to fees paid to outside managers of some active Vanguard funds, or to bank sweep revenue. Personal Advisor Select gives no credit: its fee is charged on top of fund expense ratios.
The brokerage account. Every service requires accounts at Vanguard. Vanguard Marketing Corporation’s own Form CRS (July 10, 2026) says it is paid by clients, by other fund companies through 12b-1 and shareholder servicing fees, and by its parent, Vanguard. That last payment “is generally indirectly derived from investments in Vanguard proprietary products.” It says it takes no payment for order flow.
Cash. If uninvested cash sits in the bank sweep, Vanguard Marketing Corporation receives a fee from the program banks. The brochure says clients “receive a lower yield on deposits under the bank sweep than if VMC had not earned this fee.” VAI doesn’t charge its advisory fee on money market or sweep balances.
A regulator’s order. On August 29, 2025, the SEC found that from August 2020 through December 2023, VAI’s performance reviews for advisors in Personal Advisor Services (since split into Personal Advisor and Personal Advisor Select) used metrics that gave them an incentive to enroll and retain clients, while its Form CRS and a brochure supplement said those advisors received no additional compensation. Without admitting or denying the findings, VAI accepted a censure and paid a $19.5 million penalty.
What Vanguard costs
Each service’s own published fee:
| Service | Minimum | Advisory fee per year | Fund expenses |
|---|---|---|---|
| Digital Advisor (robo) | $100 | 0.20% gross, about 0.16% net (all-index) | Credited back from the gross fee |
| Personal Advisor | $50,000 | 0.35% gross, about 0.31% net (all-index) | Credited back from the gross fee |
| Personal Advisor Select | $500,000 | 0.30% under $5 million, falling to 0.05% above $25 million | Charged on top |
| Personal Advisor Wealth Management | $5 million | No more than 0.30%, per Vanguard’s site | Not in VAI’s filings |
The active and index mix costs more: a gross 0.25% for Digital Advisor and 0.40% for Personal Advisor. Select also adds a $75 quarterly platform fee to portfolios under $450,000, with exceptions for some retirees. Its brochure says VAI may offer a negotiated fee schedule at its discretion. Wealth Management is run by Vanguard National Trust Company, a trust company regulated by the Office of the Comptroller of the Currency, so it isn’t described in VAI’s Form ADV.
Worked examples, all-index setting, fund expenses extra:
- $500,000: Digital Advisor about $800 net, Personal Advisor about $1,550 net, Personal Advisor Select $1,500.
- $1 million: Digital Advisor about $1,600, Personal Advisor about $3,100, Personal Advisor Select $3,000.
Those are well below the fee-only medians. Among fee-only firms that publish prices, ongoing planning has a median of $4,500 a year (middle half $2,400 to $7,200), and the median percentage fee is 1%, or $10,000 on $1 million at that rate. A planner’s fee may also cover tax, estate and insurance planning, so compare what’s included, not only the price. A one-time plan from a fee-only planner has a median of $2,000, which some investors pair with a low-cost portfolio they run themselves. Our guide to what a financial advisor costs on $1 million compares the models.
Who Vanguard may suit
- Investors who want a low-cost, mostly index portfolio of Vanguard funds and are happy to keep everything at Vanguard.
- People who want a robo-advisor with a very low minimum (Digital Advisor, $100) or access to an advisor from $50,000 (Personal Advisor).
- Households with $500,000 or more who want an advisor and a fee that falls as assets grow (Personal Advisor Select).
It fits less well if you want advice on investments outside Vanguard, since lead recommendations are Vanguard funds, or a planner paid only by you with no related company earning from your holdings or cash.
How to check it yourself
- Read Vanguard Advisers’ Form CRS and the brochure for the service you’re considering, at the SEC’s adviser search.
- In Form ADV Part 1, check Item 5E (how VAI is paid), Item 6A (other businesses) and Item 7A (related companies). Our guide to telling whether an advisor is fee-only shows where each one is.
- Look up Vanguard Marketing Corporation on BrokerCheck and read its Form CRS for the brokerage side.
- Ask: “What’s my net advisory fee after the credit, and what do I pay in fund expenses, in dollars?” and “Where does my cash sit, and what does Vanguard earn on it?” More in our questions to ask a financial advisor.
For how Vanguard’s model compares with other ways advisors are paid, see fee-only vs fee-based vs commission and robo-advisor vs financial advisor.
Compare similar firms
Other fund companies and digital advisers we’ve checked against the fee-only definition: Fidelity, Schwab, Betterment, Wealthfront, Empower, Facet, TIAA. See all 50 firms.