The regulatory environment in the UK makes it difficult for no-fee ETFs to launch, according to Adam Laird, head of ETF Strategy for Northern Europe at Lyxor.
ETFs are passive investment products that are listed on stock markets. Their zero-fee versions often use stock lending, which is the practice of lending shares in a listed company to another party, such as short-sellers, for a fixed period of time in exchange for a fee.
Fidelity launched a range of ETFs with zero fees in the US last August.
But unlike in the US, in the UK firms engaging in stock lending are not allowed to keep the income from it, they have to pass it on to the end client.
Mr Laird said: "I think it's conceivable these products could launch in the UK, but regulation means an element of the business model is different.
"Zero fee ETFs in the US often use stock lending, and in the US the asset manager is permitted to keep the revenue from that activity, in the UK, ETF providers must pass all of that revenue on to the client."
Another issue, he said, was the size of the UK market when compared with its US counterpart. He questioned whether the UK market was large enough for firms to achieve the scale necessary to make zero fee ETFs viable in the UK.
He said: "I don’t think any of them have gathered significant amounts of assets, I think people are skeptical about zero fees."
Paul Gibson, an adviser at Granite Financial Planning in Aberdeen, who uses passive investment products for clients on a regular basis, agreed.
He said: "The US market is far larger in scale so loss leading for the platforms concerned who are relying on dealing commissions to generate income.
"I can’t see this gaining traction in the UK given the size of the market."
Other industry experts said advisers should be wary of any zero-fee ETF that comes to the UK market because of potential drawbacks.
Hector McNeil, founder of HanETF and a former chief executive of the Wisdom Tree and Boost ETF businesses, said: "It’s worth remembering zero fund fees are a misnomer - it’s like when you apply for a mortgage and see all the special offers, but when you look at the small print you see all sorts of clauses.
"Essentially, it’s just a gimmick to get people on to a given platform to start with."
He added price should only be one factor when making an investment choice.
He said: "For example, while you may pay zero fees for one tracker, you may have to shift your money on to a specific platform, which could cost more money and leave you out of the market for a significant period of time.
"Furthermore, there is the risk that you may also then find you have a limited choice of other funds or products assuming you do not only buy the single, zero-fee tracker."
