The insurer is accountable for what the adviser cannot guarantee

Dutch pension communication under Wtp: Why insurers bear the accountability their advisers cannot

Picture a pension adviser sitting across from an SME employer in the Netherlands, somewhere in early 2025, 47 employees, manufacturing. The agenda is the transition to the Wet toekomst pensioenen (The Future Pensions Act, or Wtp). They discuss contract duration, compensation, grandfathering provisions. They discuss costs. The participants are not mentioned.

Three months later, a warehouse worker receives a transition overview (transitieoverzicht). It shows two numbers: what he had, and what he will get. The accompanying explanation is generic; the same text as the 24-year-old intern and the 58-year-old warehouse manager received.

The accountability for that explanation does not sit with the adviser, not with the employer but with the insurer. (Source: AFM supervision page, pension providers)

A chain built for certainty, not for explanation

The fact that insurers have long relied on employers and advisers to mediate participant communication had its reasons.

Under the old system, the insurer administered a defined benefit scheme - a final salary or career-average arrangement. The promise was fixed: a certain percentage of salary, at a certain age. Participants did not need to understand risk, return or investment direction. They needed to work. Communication in that system was primarily confirmation: the annual UPO telling participants what had been accrued. Understanding was not required; trust was sufficient. (Source: Verbond van Verzekeraars)

The adviser was a crucial link in that chain. He knew the employer and translated the scheme into employment terms. He was the face of the pension for the employer, and, by extension, for the employee. That worked, because the product was straightforward: so much premium in, so much pension out.

The Transitiemonitor confirms that this pattern runs deep: financial advisers report that employers with insured schemes tend to delay decisions because they see no immediate urgency, and that choices are frequently driven by cost considerations rather than participant outcomes. (Source: Wtp Transitiemonitor Summer Report 2025)

What the adviser does not discuss does not reach the employee. That was acceptable when the product asked nothing of the participant but it is no longer acceptable.

What DC changes: understanding is now an outcome variable

In a defined contribution scheme, the benefit is not fixed. It depends on investment return, interest rates, lifecycle allocation, and the choices the participant makes or fails to make. This changes the fundamental nature of pension: it is no longer a promise that the participant passively receives, but an outcome that is partly determined by what he understands and decides.

This has direct consequences for who is held accountable when things go wrong.

The AFM supervises pension providers on the quality of participant communication. The standard is clear: information must be correct, balanced, clear and timely. That accountability rests with the insurer, regardless of what the chain above it looks like. (Source: AFM supervision page, pension providers)

The Wtp added a further obligation: keuzebegeleiding (choice guidance). Since the Act came into force, insurers are required to build and maintain a digital choice environment that enables participants to make appropriate decisions. This is an open norm - the AFM will assess whether it genuinely leads to well-informed choices, not merely whether a PDF was dispatched. (Source: Werkenaanonspensioen.nl, keuzebegeleiding; Parliamentary document 2025Z18781)

Nationale-Nederlanden's pension communications specialist put it plainly in an interview with the Verbond van Verzekeraars: for a complete personal picture of a participant's situation, they need to go to their adviser - that is something the insurer cannot provide. The chain has a structural limit built into it. (Source: Verbond van Verzekeraars, keuzebegeleiding interview)

But the AFM assesses the insurer, not the chain.

What the AFM has already found

Over the past year, the AFM has conducted detailed research into the transition communication of insurers and PPIs. Its findings are specific, documented and shared sector-wide. They are the predictable output of an architecture that was never built for what is now being asked of it.

Finding 1: generic explanations. In its Platform Pensioentransitie report of March 2025, the AFM found that explanations in transition overviews are overwhelmingly generic: all participants receive the same text regardless of age, accrued capital or lifecycle stage. Insurers are not using conditional text blocks that reflect the participant's personal situation. (Source: AFM Platform Pensioentransitie, March 2025)

Finding 2: calculation errors. According to Pensioen Pro's reporting on the AFM Lessons Learned publication of September 2025, the AFM found substantive calculation errors in the transition communication of multiple insurers and PPIs: errors in the very information participants rely on to make financial decisions. (Source: Pensioen Pro, 16 October 2025; AFM Lessons Learned, September 2025)

Finding 3: unrealistic expectations. Both in the Lessons Learned and in earlier transition bulletins, the AFM repeatedly flags the risk that transition communication creates unrealistic expectations, particularly when optimistic scenario figures are shown prominently without adequate contextualisation of downside risk. (Source: AFM Lessons Learned / Transitiebulletin, October 2025)

In its letter to the Minister of Social Affairs of 24 January 2025, the regulator stated plainly that the regulator has "serious concerns" (ernstige zorgen) about the timeliness and quality of transition communication by insurers and PPIs. (Source: AFM first observations, 24 January 2025; confirmed in Government Commissioner Third Report, June 2025)

Keuzebegeleiding: structural opportunity or structural risk?

The keuzebegeleiding norm (Article 48a Pensioenwet) introduces something new: a mandatory direct channel between insurer and participant. Not via the adviser or via the employer. The insurer must build a choice environment of its own: one that places the participant in a position to make an appropriate decision, given their own objectives. (Source: AFM, keuzebegeleiding)

This is a structural change in how the chain works. For the first time, the insurer is not dependent on the adviser to reach the participant and the insurer is assessed directly on whether that participant is genuinely helped.

The open norm creates space. Insurers who build the choice environment as a compliance minimum may satisfy the letter of the requirement. The AFM will assess whether they satisfy the intent: whether participants are genuinely guided through choices that can have large and irreversible consequences for their retirement income.

The difference between those two outcomes is the infrastructure being built today.

Personalisation at scale: an infrastructure problem

Insurers and PPIs administer around 57,000 contracts covering approximately 1.5 million active participants. (Source: NOS, November 2025; Verbond van Verzekeraars)

Generic communication at that scale is the logical result of an execution process that was never set up for personalisation because at this scale, with manual processes, it was operationally infeasible.

That is the real reason why a 58-year-old warehouse manager and a 24-year-old intern receive the same explanation - because the calculation work and contextualisation are not automated.

KidbrookeOne provides the forecasting, planning and scenario simulation APIs that allow insurers to build participant-level personalisation into their communication infrastructure without a major transformation project. The integration sits between the insurer's existing data and the participant-facing interface, making the AFM's requirement for personal explanations operationally feasible at the scale of the insured book.

In the next blog in this series, we look at the transition overview itself: why the distinction between a compliance document and a genuine communication act plays out very differently for insurers, with their mixed DB/DC books, than it does for PPIs.

Sources:

1. AFM — Supervision of pension providers

2. Wtp Transitiemonitor Summer Report 2025 (EY/SZW)

3. Verbond van Verzekeraars — Pensions

4. AFM first observations, letter to Minister Van Hijum, 24 January 2025

5. AFM Platform Pensioentransitie report, March 2025

6. Pensioen Pro — AFM finds substantive errors in insurer communication, 16 October 2025

7. AFM Transitiebulletin / Lessons Learned transition communication insurers and PPIs, October 2025

8. Government Commissioner Third Report, 19 June 2025

9. AFM — Keuzebegeleiding (guidance and supervision)

10. Werkenaanonspensioen.nl — Keuzebegeleiding

11. Parliamentary document 2025Z18781, 7 October 2025 — keuzebegeleiding and open norm

12. Verbond van Verzekeraars — Interview Ellen Kraft (Nationale-Nederlanden), keuzebegeleiding

13. NOS — Tax risk looms for 1.6 million pension policyholders, November 2025