
Published on April 28, 2026
Picture a pension adviser in an annual review with an employer: 80 employees, logistics, early 2026. The transitieplan is signed. The transition date is January 2027. The adviser has done his job on the employer side: scheme design, compensation, eerbiedigende werking, offerte.
The employer asks: 'What should I tell my employees when they get the transitieoverzicht?'
The adviser does not have an answer. He knows the scheme but he does not know what the was/wordt comparison looks like for a 52-year-old driver with sixteen years of middelloon accrual, or what it looks like for a 28-year-old who joined last year. That distinction matters, the AFM has said so repeatedly but nothing in his current toolkit allows him to show it.
The insurer has the participant data, the adviser has the employer relationship. Neither has connected them.
This is the third in a series on the insurer's role in the WTP transition. The first established where accountability sits when the adviser cannot guarantee participant outcomes. The second examined why the transitieoverzicht is a document, not a communication — and what that distinction costs participants. This post looks at what closing that gap actually requires in practice.
The AFM's position on this is not ambiguous. In 2024, the regulator conducted conversations with pension advisers about their role during the transition. Those conversations produced four conclusions, of which the third speaks directly to the question above: informing employees about their choices is a shared responsibility, both the adviser and the pension provider have a role.
The same page notes that maatwerk advice under Article 4:23 Wft remains fully available to advisers during the transition period. The adviser who is equipped to give participant-level guidance has a clear regulatory basis for doing so. The question is not whether the role exists but whether the tools exist to fill it. (Source: AFM — Pensioenverzekeringen / Pensioenadvies tijdens pensioentransitie)
The joint Adfiz–Verbond guidance on transitieplannen reinforces this at the employer level. The adviser is positioned as the person responsible for ensuring the employer includes comprehensible participant-facing explanations in the transitieplan; texts that, according to the guidance, should be written with the participant's understanding in mind, not just legal sufficiency. (Source: Adfiz / Verbond van Verzekeraars — handleiding transitieplan)
The adviser is not a distribution channel who hands off once the contract is placed. He is, by the AFM's own framing, a co-responsible actor in the communication chain, whose reach into the employer relationship gives him access to the participant population at precisely the moment it matters most.
The adviser's current workflow is built around scheme-level decisions: premium structure, lifecycle options, compensation framework, offerte. It was not designed to produce participant-level scenario analysis. Without a calculation tool that connects the insurer's participant data to the adviser's client-facing materials, the employer question 'what should I tell my employees?' has no analytical answer. The adviser defaults to a general explanation of how DC works. The participant receives a transitieoverzicht that was not preceded by any employer-mediated context.
The operational pressure on advisers makes this structural gap harder to close with effort alone. The Government Commissioner's fourth report, published in January 2026, describes pension advisers as having an aanjagende rol, a responsibility to push employers toward timely conversion, while noting that this role is not being fulfilled by every adviser, particularly those for whom pension is not a primary activity. The number of qualified pension advisers has decreased, adding pressure to those who are active. Conversion takes between two and six quarters on average. Advisers who are fully committed to driving scheme conversions in 2026 and 2027 will not build participant communication capability alongside that unless the tooling makes it operationally light. (Source: Regeringscommissaris transitie pensioenen — Fourth Report, January 2026)
In January 2026, the AFM wrote directly to more than 900 pension offices, designating 2026 as the decisive year. An advice and conversion process takes up to 18 months in practice. The AFM was still receiving signals that not all advisers had begun. The adviser population is at maximum capacity on the scheme side. Participant communication capability will only be built if it is integrated into existing adviser workflow not added as a separate manual process on top of an already overloaded pipeline. (Source: AFM — letter to pension advisers, January 2026)
The insurer as the single regulated entity is the only party in the chain that holds three things simultaneously: the participant data, the full product, and the regulatory communication obligation. The adviser has the employer relationship. The employer has the workforce. But the insurer is the only entity with both the calculation inputs and the AFM accountability, which means the insurer is the only party that can connect the adviser's employer relationship to a participant-level communication capability.
This product completeness also distinguishes the insurer structurally from PPIs. A PPI cannot carry insurance risk. It cannot offer guaranteed outcomes, nabestaandenpensioen, or disability cover directly, these must be outsourced to a verzekeraar. The insurer who tools the adviser for participant communication therefore strengthens not just the communication proposition but the entire product relationship: the adviser can have a coherent conversation about the full package, accumulation, risk cover, and participant guidance, from a single calculation foundation. (Source: Verbond van Verzekeraars — Premiepensioeninstellingen)
The practical change is specific. In the annual review meeting with the employer, the adviser can pull the was/wordt projection for the relevant age cohorts in that workforce, not a generic DC explanation, but the actual scenario distribution for participants with this company's profile, contribution base, and transition mechanics. He can show the employer what the transition looks like for the 45–54 cohort. He can show why the scenario spread is particularly wide for someone five years from retirement transitioning from a middelloon arrangement.
The employer who has seen that simulation is better positioned to brief their employees before the transitieoverzicht arrives. The AFM has consistently said that communication around the transition moment should be coherent as a whole, that the document, the choice environment, and any preceding communication should add up to a participant who understands their situation. An employer conversation built on participant-level scenario analysis is part of that coherent chain.
The participant who receives a transitieoverzicht that their employer has already contextualised 'your pension adviser showed us what this means for people in your situation' arrives at the keuzebegeleiding environment with a different level of preparation. The digital choice environment can go further, faster, because the groundwork was laid in the employer conversation.
The adviser's employer conversation and the participant's keuzebegeleiding environment do not need to be separate systems built on separate logic. KidbrookeOne provides the forecasting, planning and scenario simulation APIs that allow insurers to surface participant-specific was/wordt projections and outcome distributions at both points in the chain, without rebuilding the entire tech stack. The Advice APIs generate scenario-ready outputs from the insurer's existing participant data, usable in the adviser's workflow. The Customer Portal APIs and scenario simulation tools extend the same calculation layer into the participant-facing environment.
What the adviser showed at cohort level, the participant can explore at the personal level. The communication is coherent because the underlying analytics fabric is shared. The AFM's requirement, that transition communication add up to a participant who understands their situation, becomes operationally achievable rather than aspirationally stated.
Part of a series: The insurer's role in the WTP transition
The insurer is accountable for what the adviser cannot guarantee. Why the regulated entity in the chain cannot hand off communication responsibility — and what that means commercially.
The transition overview is not communication. It is a document. The transitieoverzicht arrives. The participant is unprepared. Who is responsible for the gap?
The adviser is your strongest argument — if you give him the tools. You are here.
Sources:
2. Adfiz / Verbond van Verzekeraars — handleiding transitieplan met tekstvoorbeelden, June 2025
3. Regeringscommissaris transitie pensioenen — Fourth Report: aanjagende rol adviseurs, January 2026
4. AFM — letter to 900+ pension offices: 2026 decisive transition year, January 2026
5. Verbond van Verzekeraars — Premiepensioeninstellingen: product limitations vs insurers