The transition overview is not communication. It is a document.

Why the transitieoverzicht satisfies a legal obligation but does not communicate, and what it takes to fix that at scale.

Picture an insurer that did everything right. Legal reviewed the transition overview. The communication team worked on layout and readability. The figures are correct. The document goes out on time.

A participant who spent fifteen years in a middelloon scheme opens it. She sees two columns: what she had under the old arrangement, what she will have under the new DC scheme. In the good-weather scenario, the new DC figure is higher than her old projected benefit.

She draws the obvious conclusion: the new scheme is better. She files the document away and stops thinking about her pension.

Nobody explained that the good-weather scenario is not the expected outcome or that for a participant her age, the spread between the optimistic and pessimistic scenarios is very wide. Nobody explained that the nature of her accrual promise changes, from a guaranteed percentage of career-average salary to a DC pot whose value depends on investment returns and the choices she makes.

The transition overview satisfied its legal obligation. It did not communicate. The AFM has been saying this, in progressively more direct language, since late 2023. As of April 2025, it was still saying it: personal explanations alongside scenario amounts on transition overviews are still not sufficient. (Source: AFM, April 2025)

What the transitieoverzicht is, and what it was never meant to do

The transitieoverzicht is a statutory instrument. The AFM defines its purpose as giving participants a timely, correct, clear and balanced personal picture of the consequences of the move to the new pension scheme, including what their expected pension will look like under both the old and new arrangements. Two documents are required: a forecast overview (prognose-transitieoverzicht) at least one month before the transition date, and a definitive overview within six months after. (Source: AFM transitieoverzichten page)

That is a demanding standard. Three scenario amounts in two columns — old regime, new regime — are the minimum form. Whether they produce a clear and balanced personal picture is a different question.

The agreement between the AFM and the sector dates to late 2023. Scenario amounts in the new scheme can be significantly higher than what participants had under their old guaranteed arrangement, because of the removal of the 'enough-is-enough' principle, the distribution of buffers, and the assumptions built into the calculation methodology. The risk of unrealistic expectations was identified clearly at that point. The sector agreed to address it by adding personal explanations alongside the scenario amounts. (Source: AFM, April 2025)

That agreement has not been fulfilled consistently. The personal explanations are still largely absent. What most participants receive is a document that shows them numbers — correctly calculated, properly formatted — but does not help them understand what those numbers mean for them specifically.

There is an important distinction here between a disclosure obligation and a communication act. The transitieoverzicht, as it is currently being produced by most insurers, satisfies the former. The AFM requires the latter.

Why this is most acute for insurers: the mixed-book problem

Every pension provider faces the generic/personal problem. But insurers face the hardest version of it, for structural reasons that have nothing to do with effort or intent.

The overwhelming majority of insurer contracts still to convert were previously DB or middelloon arrangements — guaranteed schemes in which the participant had no investment risk and no real choices to make. At the time of the Transitiemonitor Summer Report 2025, 93% of insurer contracts had not yet been converted, covering approximately 57,000 contracts and 1.5 million active participants. The vast majority of those participants are making their first real encounter with DC — with variable outcomes, scenario amounts, and investment choices — through the transitieoverzicht. (Source: Wtp Transitiemonitor Summer Report 2025)

For those participants, the was/wordt comparison is not just two numbers in two columns. It is a transition from one type of promise to an entirely different one. Under a middelloon arrangement, the participant was owed a fixed benefit: a guaranteed percentage of career-average salary, for life, from a specified retirement age. Under DC, the participant holds a pot of invested capital whose eventual value depends on returns, interest rates, and the choices they make. The AFM's Sector in Beeld 2025 found that for younger participants in particular, the spread between the good-weather and bad-weather scenario in the new scheme can be very large — and that without context, these widely divergent amounts are likely to create exactly the unrealistic expectations the sector promised to prevent. (Source: AFM Sector in Beeld 2025, May 2025)

A participant who spent fifteen years in a guaranteed middelloon scheme and has five years until retirement needs a fundamentally different explanation of the was/wordt comparison than a 31-year-old who has only ever been on DC. Their old scheme produced a fixed promised benefit. Their new DC scheme starts from a different contribution base, accumulates under different assumptions, and carries risks the old scheme insulated them from entirely. The interplay between frozen old-regime rights and new DC accrual is personal, complex, and consequential. A generic scenario document cannot explain it.

A second layer of complexity applies where employers choose eerbiedigende werking; the transitional arrangement that allows existing employees to remain on a rising premium structure while new employees go directly to the flat DC premium. The government's own guidance acknowledges explicitly that running two parallel schemes within a single employer contract 'can have consequences for comprehensibility' for participants. An insurer book in which many employers have chosen eerbiedigende werking contains two distinct participant populations within the same contracts, and even within the same employer whose situations cannot be explained in the same terms. (Source: Werkenaanonspensioen.nl — eerbiedigende werking)

What 'personal' actually means, and why it is not a copywriting problem

The AFM has been specific about what personal explanations require. In its January 2025 first observations, it found that all participants receive the same text because providers are not using conditional text blocks that appear only when relevant to that participant's situation. The AFM gave a direct example: a 30-year-old should not receive the explanatory text written for someone over 50. Other examples included explanations about eligibility for temporary old-age pension, about whether compensation applies, and about partner pension — all of which are highly participant-specific. (Source: AFM eerste observaties, January 2025)

This is a more fundamental requirement than it might appear. Conditional text blocks are not a formatting exercise — they require the system generating the communication to know which conditions apply to each participant and to select the appropriate explanation accordingly. That is a data and computation problem, not a drafting problem.

Writing better letter templates does not solve it. You cannot template your way to personalisation when the relevant variables — age, accrual history, scheme type, lifecycle position, whether eerbiedigende werking applies, the specific was/wordt comparison basis for this participant — are different for every person in the book. The only way to produce genuinely conditional, participant-specific communication at scale is to automate the calculation and contextualisation layer.

The AFM's Lessons Learned publication on insurer and PPI transition communication (September 2025) reinforces this with three specific aandachtspunten: bring the personal consequences of the transition into view in a balanced way and prevent unrealistic expectations; enable participants to make a genuine comparison between the old and new scheme; and ensure that communication around the transition moment is coherent as a whole. All three require participant-level information as input. None can be produced from a generic template. (Source: AFM Transitiebulletin / Lessons Learned, October 2025)

The direction of travel from the AFM has been consistent. In May 2025, it recommended that insurers build a personal digital dossier for each participant — a single accessible place where all transition communication relevant to that individual is gathered. It is an infrastructural recommendation. (Source: AFM, May 2025 — persoonlijk transitiedossier)

The document and the choice environment are two different instruments

The combination of the transitieoverzicht obligation and the keuzebegeleiding norm has created a two-part communication framework, whether or not insurers are treating it as one. The transitieoverzicht is the statutory disclosure: what changed, expressed as scenario amounts, in a document the insurer is legally required to produce and dispatch. The keuzebegeleiding environment is the communication act: an interactive digital environment that helps participants understand what those numbers mean, model the consequences of different choices, and arrive at decisions that are actually appropriate for their situation. The AFM supervises both — and assesses them on whether they genuinely work for participants, not just whether they formally exist. (Source: AFM — keuzebegeleiding)

The distinction matters because the two instruments have different jobs. The transitieoverzicht is backward-looking and point-in-time: it tells the participant what has happened to their accrual as a result of the transition. The keuzebegeleiding environment is forward-looking and interactive: it helps the participant understand what it means and what they can do about it.

Insurers that treat the transitieoverzicht as the primary communication instrument and the keuzebegeleiding environment as a supplementary legal checkbox are asking one instrument to do both jobs. A document that shows three scenario amounts, however correctly calculated and clearly formatted, cannot help a participant understand why the spread between good and bad weather is as wide as it is for someone their age. It can neither model what happens if they adjust their contribution level nor show the difference between the lifecycle their money is currently following and the alternatives available to them. These are interactive, participant-specific conversations. They require a choice environment.

Solving a computation problem, not a content problem

The reason most insurer transition communication remains generic is not that the insurers have not thought carefully about the problem. It is that generating participant-specific was/wordt modelling, one that reflects each participant's actual accrual history, their specific transition mechanics, their age and lifecycle position, and their precise was/wordt comparison basis, is an infrastructural problem. It cannot be solved with better templates, because the information that makes it personal is different for every participant in the book.

At the scale of 57,000 contracts and 1.5 million participants, that infrastructural problem cannot be solved with manual processes. The only operationally feasible path is to automate the underlying analytics fabric: to integrate a forecasting and scenario engine that takes each participant's actual data as inputs and generates genuinely personal outputs: personal explanations, personal scenario context, personal was/wordt comparisons rather than applying uniform text to everyone.

KidbrookeOne provides the forecasting, planning and scenario simulation APIs that allow insurers to build participant-level personalisation into their communication infrastructure without rebuilding the entire tech stack. The Advice APIs can generate the was/wordt comparison as a participant-specific calculation rather than a document template. The Customer Portal APIs and scenario simulation tools enable the interactive keuzebegeleiding environment the AFM requires - one that places the participant's own numbers in context, allows them to model different choices, and shows the distribution of outcomes rather than three point estimates.

The integration sits between the insurer's existing data and the participant-facing interface. The transitieoverzicht remains the statutory starting point. The keuzebegeleiding environment, built on the right calculation infrastructure, is where communication actually happens.

Sources:

1. AFM — Personal explanations in transition overviews still not sufficient, April 2025

2. AFM — Transitieoverzichten: purpose, requirements and supervision

3. AFM eerste observaties, letter to Minister Van Hijum, 24 January 2025

4. AFM — Good practices insurers: Lessons Learned transition communication, October 2025

5. AFM Sector in Beeld 2025 — wide scenario spread for younger participants, May 2025

6. AFM — Build a personal transition dossier for every participant, May 2025

7. AFM — Keuzebegeleiding (guidance and supervision)

8. Wtp Transitiemonitor Summer Report 2025 — 93% of insurer contracts still to convert

9. Werkenaanonspensioen.nl — Eerbiedigende werking: comprehensibility consequences

10. Nationale-Nederlanden — From DB to DC: what changes for participants