The 3.5 kW heater will have a tank reservoir that will have time to heat up the water when it's not being used. Tankless means it has to be heated instantly.
It takes ~ 4 kJ to heat 1 kg of water for each 1°C. If you want to do that in 1 second, you need 4 kW of heating power.
So if a shower uses, say, 9 litres per minute, i.e. 0.15 litres per second, heating that water from 10°C (typical cold water temperature) to 40°C (comfortable shower temperature) is:
4 • 0.15 • 30 = 18 kW
Anything less heats less water per second, or to a lower temperature.
Like this 5.1 l/min unit at 9.5 kW will be able to heat that flowrate ~28°C above its inlet temperature.
And we got to get ourselves
Back to the garden