What is DNB’s role?
In our supervision of pension funds, we look at the following:
Financial position
Do pension funds comply with the statutory financial rules and regulations – for example with respect to investments and contributions, and when increasing or decreasing pension entitlements and benefits?
Operational management
Do pension funds have their bookkeeping and accounting systems in order? Have pension fund properly identified the risks involved in administering a pension scheme, and are there policies in place to manage these risks?
Board members
Are a pension fund's board members suitable for their job, and is their integrity beyond doubt? They may only join the board following approval by DNB.
DNB also assesses the conversion to the new system
When converting to the new system, pension funds must transfer the collectively accrued pension capital to individual pension accounts. It is crucial that calculations, data quality and IT systems are robust so that all pension entitlements are correctly converted to the new system. When a pension fund is ready to convert, DNB assesses whether the conversion will take place in a ‘transparent, controlled and careful’ manner and whether all members can feel that they are represented in a balanced way.
What does this mean?
Clear rules are in place to ensure that members’ interests are properly balanced. Pension funds must carefully assess the financial implications and use these figures when making their decisions. There are also rules governing the 'transition instruments’ that they use when distributing the accrued capital. These instruments include the calculation method, how any buffer is to be funded, and what compensation members will receive for the abolition of the ‘one-size-fits-all’ system (under which every euro contributed results in the same pension accrual for all pension scheme members, regardless of their age).
In addition, DNB oversees the smooth conversion to the new system. Funds must identify and manage risks, such as errors in data or problems with IT systems, in a timely manner. Finally, DNB checks whether the decision-making process within the fund was conducted with due care.
Statement of views on conversion plan
The pension fund must make a conversion plan available to its members on its website. The members must then be given an opportunity to submit a statement of views about the intended conversion before DNB takes a decision. DNB collects and considers the statements of views in its decision. Submitting a statement of views is subject to certain conditions. The conditions for submitting a statement of views on a conversion plan are described on DNB’s website (in Dutch).
Statement of views on bridging plan
If a pension fund wishes to use transition instruments for increasing and decreasing pensions, it must submit an annual bridging plan to DNB for each year of the transitional period, setting out the fund’s financial situation until the moment of conversion. Funds that intend to convert to the new system on 1 January 2028 must submit a bridging plan by 1 April 2027 at the latest. Members can also submit a statement of views on a pension fund’s bridging plan under certain conditions. Information on submitting a statement of views can be found here (in Dutch).
Once a pension fund has converted to the new system, DNB continues to supervise whether its bookkeeping and accounting systems are in order.