Scramble Review 2026: 20/50, Fair

Why Scramble scores 2/10 on investor protection

Scramble operates without regulatory oversight from any European financial authority. Our investor protection criterion scores platforms on licence type and the presence of a compensation fund. MiFID II licences score highest, ECSP licences rank next, and unregulated platforms score at the bottom. Scramble holds no licence and therefore scores 2/10, the minimum tier reserved for platforms that operate outside any regulatory framework. No compensation scheme covers borrower defaults on Scramble, and investors have no recourse to a statutory fund in the event of platform failure or loan loss.

Why Scramble scores 4/10 on track record

Scramble has operated since 2020, giving it just under six years of history. It reports EUR 14.67 million in cumulative volume, a figure substantially lower than most peers in our ranking. Our track record criterion rewards platforms with a longer operational history, higher reported volume, and a buyback guarantee that has a credible track record behind it. Scramble has no buyback guarantee and a limited volume history, so it scores 4/10 in this category. Platforms that score 7/10 or higher typically have at least eight years of operation and have processed hundreds of millions in volume.

Why Scramble scores 3/10 on return transparency

Scramble advertises a target return range of 12.4-25%, a spread of 12.6 percentage points. Our return transparency criterion penalises wide advertised ranges because they give investors little certainty about what they will actually earn. A narrow range signals that a platform either standardises interest rates or publishes specific, predictable rate structures. Scramble's double-digit spread scores 3/10, well below the 8/10 or 9/10 earned by platforms that publish a 1-3 percentage-point target band. The upper end of Scramble's range is the highest among all 19 platforms we track, but without a narrow, published rate or a history of realised returns to validate that advertised figure, the transparency score remains low.

Why Scramble scores 7/10 on structural clarity

Scramble focuses exclusively on business loans, and it reports EUR 14.67 million as a cumulative volume figure rather than a single snapshot of assets under management. Our structural clarity criterion scores platforms on the diversity of loan types they offer and whether they publish cumulative volume or only a single AUM number. A single loan type is less diverse than a platform that offers consumer, real estate and business loans, but cumulative reporting is more transparent than a single snapshot because it shows the total flow of capital processed since inception. Scramble scores 7/10 in this category, higher than platforms that report only AUM or that concentrate in a single loan type without cumulative disclosure.

Why Scramble scores 4/10 on liquidity and exit

Scramble offers no secondary market and no buyback guarantee. Once you invest in a business loan on Scramble, you hold that loan until it matures or defaults. The EUR 10 minimum investment is low and scores positively in our method, but the absence of any early-exit mechanism caps the liquidity score at 4/10. Platforms that offer a functioning secondary market, such as Mintos, Twino or Capitalia, score 8/10 or higher in this category. Platforms with both a secondary market and a buyback guarantee can reach 10/10 if the minimum investment is also low.

How investing on Scramble works

1. Create an account

   Register with an email address and complete KYC verification by uploading a passport or ID card and proof of address. Scramble will confirm your identity before you can deposit funds.

2. Deposit capital

   Transfer EUR via bank transfer to your Scramble wallet. The minimum investment per loan is EUR 10, so you can start with a small allocation and add more later if you choose.

3. Select loans manually

   Browse available business loans and choose individual opportunities based on interest rate, duration and any published borrower information. There is no auto-invest feature mentioned in our data, so assume you select each loan manually.

4. Hold to maturity or default

   Once invested, you hold the loan until it repays or defaults. Scramble has no secondary market, so you cannot sell your position early. Repayments return to your wallet, where you can reinvest or withdraw.

Who Scramble suits

Scramble ranks last in our 19-platform ranking and operates without regulatory oversight, so it suits only investors who accept unregulated exposure and who prioritise high advertised returns over structural protections. The 12.4-25% target range includes the highest upper bound in our dataset, but that figure is advertised, not guaranteed, and the wide spread means actual returns could land anywhere in that range or below it if defaults occur. Investors who require a secondary market, a buyback guarantee, or a platform regulated under MiFID II or ECSP rules will find better-scoring alternatives in our ranking. Scramble may appeal to experienced P2P investors who already hold positions in higher-ranked platforms and who are willing to take a small, speculative allocation in an unregulated, business-loan-focused platform with limited liquidity.

How Scramble compares

Scramble ranks 19th of 19, behind every other platform in our dataset. Reinvest24, also Estonian and unregulated, scores 21/50 and ranks 18th, one position higher, because it offers a secondary market. EstateGuru, the highest-scoring Estonian platform at 39/50, holds an ECSP licence from the Estonian Financial Supervisory Authority and offers both a secondary market and a more established track record. Investors comparing Scramble to other unregulated platforms should also review Hive5 (22/50, rank 15) and Robocash (24/50, rank 13), both of which offer a buyback guarantee that Scramble does not. For a full comparison of regulatory frameworks across all 19 platforms, see our guide on ECSP vs MiFID II vs unregulated platforms.

Verdict

Scramble scores 20/50 (Fair) and ranks 19th of 19 on our published, criteria-based method. It operates without regulatory oversight, advertises the widest target return range in our dataset, and offers no secondary market or buyback guarantee. The platform's low minimum and cumulative volume reporting are positives, but they do not outweigh the absence of structural protections that higher-ranking platforms provide. Capital is at risk, no compensation scheme covers borrower defaults, and investors should verify all terms directly with Scramble before committing funds. For a full view of how Scramble compares to all 19 tracked platforms, visit our full ranking or browse all reviews.