She leaves no room for misunderstanding; Government Commissioner Fieke van der Lecq is optimistic about the progress the sector is making in the transition to the renewed pension system by January 1, 2028. Yet in her first report to the Ministry of Social Affairs and Employment (SZW), she also identifies areas for improvement. “Talk to each other more, share knowledge and thus ensure a rising learning curve.”
We spoke to Van der Lecq during the Summer Course in Lunteren, organized by APG. Her presentation to the room full of pension fund managers and APG staff showed once again that the transition is “top of mind”. There are plenty of questions for the government commissioner. There are also uncertainties. In her first of at least three reports in which Van der Lecq advises on the progress of the transition to the renewed pension system, she also makes the latter clear.
For example, Van der Lecq believes regulators should provide more clarity on how to comply with the legal framework. “Especially in the beginning, the sector needs some degree of coaching. Although the system parties themselves remain responsible for their implementation processes, of course.” She also takes a clear position regarding politicians and the Ministry of Social Affairs and Employment (SZW): Act on the already announced improvements in laws and regulations now. And avoid new and radical changes.
Why do you insist so emphatically on the latter?
“You want prevent a situation where there is a group of funds that have already transitioned and there is another group that hasn’t transitioned yet, to which different rules apply. That would create legal inequality.
Moreover, drastic changes in legislation take the momentum out of the process of submitting and assessing transition and communication plans. This is not what we want. It is essential for funds, administrators and regulators that there is calmness and clarity about the laws and regulations. After all, based on the current rules, we need all of our capacity to get through the transition. Incidentally, I am seeing that the legislation and regulations are becoming more and more concrete.
Remaining points are increasingly being fleshed out. Things are really moving in the right direction. Parties have more and more clarity on where they are going.”
Despite the inevitable bottlenecks, you are not worried whether the target date of January 1, 2028 will be met by the sector. Why not?
“I am seeing an enormous drive and decisiveness among the chain parties. That is one thing. In addition, most funds are heading for a transition in 2026 or early 2027. So, there is room in the planning until 2028, should things unexpectedly turn out differently. It is also in the funds’ interest to transition soon, because a lot can happen in terms of interest rates and other variables in the meantime. Funding ratios can change as a result, which in turn can be grounds for overturning earlier agreements on balance and redistribution.”
Several funds that were scheduled for January 1, 2025 have delayed their transition. What do you think is the reason for this?
“It turns out that in some cases DNB and the AFM are still asking for more than the funds had expected. That surprised a few and led to a delay. This makes sense, by the way: it is all new and a process of invention. In some cases, the administrative organization is not yet ready. This is often on the IT side. Processes have not yet been set up with sufficient reliability. Is that a bad thing? No, not at all. It is not a failure, but a wise decision. But if everyone delays the transition, we will have a problem at the end. But I don’t expect that to happen; most of the big funds are ready for 2026. And at present, that is quite feasible.”
What would you say to the funds that are the first to transition, including PWRI and PPF APG?
“I am a fan of early adopters. This is because they are very important for the next step. They show society that it can be done, that the transition is doable. They set a good example. Plus, they can share their learning effects with other funds that are facing a transition.”
Does the latter happen enough?
“Yes and no. I see a great willingness to learn, among supervisors, among funds and among administrative organizations. That is positive. Still, they could seek each other out more. But everyone is busy with their own office, so they don’t always make time for that. But my advice is really: engage in discussion about, for example, the creation of new regulations and communication with participants. The dynamism, versatility and diversity in the sector is enormous, and so is its complexity. That is also why it is important that we don’t all reinvent the wheel. So, when certain funds now know how it works, then others can learn from that and better pursue the first-time-right principle: this works, that doesn’t, that form is good, that one is not. If that learning process gets going, then we will achieve the end goal together. But beware; cut and paste is bad practice, including when it comes to the communication plan. They will see right through that at the AFM.”
Funds are not in each other’s way, but for administrative organizations the situation is different. They are each other’s competitors. How could they enter the conversation?
“No, they won’t go for coffee together anytime soon. But that is not a bad thing at all, as it creates different approaches and insights. Then you can see what works better. For example, APG has created a calendar, entirely according to the time and in consultation with fund clients. There are also administrative organizations that will transition with a big splash. In addition, they all use different IT systems. Thanks to those differences, we can clearly see what works and what doesn’t work as well.
Administrative organizations indicate that the more we can standardize, the better it is. Do you agree?
“Standardization leads to a faster, cheaper and less error-prone process. Those are three very good reasons. Anyway, you have the administrative organizations on one side and the social partners, who have negotiated their own regulations, on the other side. The pension fund is in the middle, between them. That is the area of tension. So, if an administrative organization says, “We can’t implement that scheme, it deviates too much from the standard,” then the fund has to go back to the social partners. That sometimes causes delays. That is why it is important that there is good communication and consultation. Sometimes this goes smoothly, sometimes it doesn't. Therefore, keep an eye on each other, and invest in your stakeholders. You know you need them and it's better to talk to them in advance than afterwards.”