ANALYSIS REPORT

Sector in Focus: Pensions 2026

In brief - With this publication, the AFM shares insights into important developments in the pension market, derived from reports submitted by pension administrators. The publication enables pension administrators and social partners to compare the characteristics of their own scheme and the options available to participants with the rest of the sector. In particular, we focus on three main topics: the characteristics of the defined contribution schemes of the first participants in the new pension system, the status of the group of participants who are building up little or no pension, the insights gained from our complaint survey, and how investment freedom is implemented in defined contribution schemes. This sector overview is based on 2024 data provided by the pension sector.

MAY | 2026

© AFM 2026 | Sector in Focus: Pensions 2026 2

Table of Contents

Introduction 3

1. There are significant differences in what participants in defined contribution schemes can expect from their pension 1.1 Flat premiums are easy to compare and provide an indication of the pension perspective 4 1.2 The group of employees building up pension has grown due to the reduction in the starting age 6 1.3 For an increasing number of participants, partner pension and premium continuation in case of disability are insured 6 1.4 However, data on the new system also shows that partner pension coverage can vary significantly 7

2. Complaint data provides a valuable perspective on the quality of service 2.1 The number of registered complaints varies by type of pension administrator 9 2.2 Most registered complaints concern pension calculation and payment 10 2.3 By far the majority of complaints are handled within a few weeks 11

3. Investment freedom does not lead to actual choice everywhere; young people are left behind 3.1 The majority of participants in defined contribution schemes have investment freedom 12 3.2 Little use of investment freedom, especially among young participants 13 3.3 Large differences in the use of investment freedom between pension administrators 14

4. Appendix – General 4.1 Number of pension administrators 15 4.2 Participants in the accumulation phase 15 4.3 Types of pension agreements 16 4.4 Value of pension accrual in the Netherlands 17 4.5 Benefit phase 18

5. Appendix – Benefit Agreements 5.1 Accelerating and delaying pension commencement 19 5.2 Varying benefit amounts 19 5.3 Partner pension and premium exemption 20 5.4 Restrictions on pension accrual 21 5.5 Pension at the end of the term 21

6. Appendix – Premium Agreements 6.1 Fixed/Variable pension 22 6.2 Accelerating and delaying pension commencement 23 6.3 Varying benefit amounts 23 6.4 Investment freedom 24 6.5 Partner pension and premium exemption 25 6.6 Restrictions on pension accrual 26 6.7 Pension at the end of the term 27

© AFM 2026 | Sector in Focus: Pensions 2026 3

Introduction

The Dutch pension sector is in the midst of a transition. Previously, 75% of active participants in the second pillar built up a pension in a benefit scheme. After the transition, everyone will build up a pension in a defined contribution scheme, where the amount of contributions is fixed, but the amount of the benefit depends on market conditions. This pension transition is not only impactful for the pension sector, but especially for the pension participant. Many are faced with a different pension scheme, where risks and opportunities lie more directly with themselves.

What do these changes mean in practice? How do pension schemes differ from each other now, and what do the first figures say about the consequences for participants? This report offers a unique perspective on these questions from the viewpoint of the AFM's behavioral supervision, based on the reporting year 2024 of the Supervisory Report Second Pillar Pension.1

With this report, we aim to contribute to a better substantiated image of trends and points of attention in the pension sector. By combining our data with analysis and interpretation, this report supports pension administrators, social partners, policymakers, and execution organizations in making choices in a system that is in full motion. This publication contains an extensive statistical appendix, allowing readers to track the development of certain aspects over time. The appendix consists of three parts: general insights, benefit schemes, and defined contribution schemes. The graphs in the appendix largely correspond to previous publications.

Using data, we make visible how pension schemes are developing in the new system. By the end of 2024, there were seven pension administrators with participants in the new pension system, and these were only pension insurers and PPIs (Premium Pension Institutions). This concerned a small group of approximately 75,000 participants (active and former). The first pension funds only started operating under the new pension system on January 1, 2025. Therefore, by the end of 2024, no one participated in a solidarity defined contribution scheme. The image of the new pension system will become sharper each year as more pension schemes are converted.

In the first chapters of the publication, we also highlight three topics that stood out to us in the data. These are (1) the large differences in what participants in defined contribution schemes can expect from their pension, (2) the perspective that complaint data provides on the quality of service by pension administrators, and (3) the limited share of participants who make use of the opportunity to make choices about their pension investments.

More information? You can find more information about the AFM and the Supervisory Report Second Pillar Pension on the AFM website. The website also contains a more extensive explanation of the various topics that appear in this Sector in Focus: Pensions, including an overview of our previous publications.

1 This publication is based on the reports that Dutch pension administrators have provided to the AFM as of the reference date December 31, 2024. All Dutch pension funds, pension insurers, and premium pension institutions report annually to the AFM via the Supervisory Report Second Pillar Pension. The AFM also uses the data from the Supervisory Report Second Pillar Pension to monitor the most important trends and developments in the pension sector and to maintain risk-based supervision. Based on this data, we quantify risks and prioritize themes for our supervision. The data as of the end of 2024 is the most recent available data at the time of this publication; pension administrators must submit the reports for the reference date December 31, 2025, by September 30, 2026 at the latest.

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1. There are significant differences in what participants in defined contribution schemes can expect from their pension

Participation in a second-pillar pension scheme determines, along with the AOW (General Old Age Pensions Act), the income after retirement to a large extent. Employees in wage employment who do not participate in a pension scheme are also referred to as the 'white spot'. In addition to the white spot, the term 'grey spot' is used to designate the group of participants in pension schemes who are building up a (very) small pension. This group is not clearly defined, as what constitutes a sufficient pension can vary by sector and participant population. For this reason, we follow the development of this group from various angles.

1.1 Flat premiums are easy to compare and provide an indication of the pension perspective

In a defined contribution scheme, the amount of the premium is fixed, and the amount of the pension benefit depends on market conditions such as investment returns and interest rates. This makes it easier to compare the quality of defined contribution schemes for individual participants based on the premium than with collective benefit schemes, where redistribution often occurs. The new pension system works with flat premium percentages, which are the same for all ages. This makes it easier to compare the premium amount of a younger and an older participant than in the old situation, where the premium increased with age according to a predetermined premium scale.

To illustrate: a look at the small first group of participants in the new system shows that the height of the flat premium can vary strongly between pension schemes. Despite the still limited size of the group of active participants in the new pension system, the data provides a first image of the height of the flat pension premium. For 12% of these participants, the premium percentage is 5% or less, and for 7% it is 20% or more. This image will change in the coming years as more participants move to the new pension system. In particular, for benefit agreements that are transferred to the new system, social partners have agreed on higher premium percentages.

Figure 1: Percentage of participants split by premium percentage for schemes in the new system

What does Figure 1 show? The graph shows the distribution of participants in the new system by the height of the premium percentage in their pension scheme. For 7% of participants, the premium is 20% or more of the pension base, for 47% of participants the premium is between 11% and 20%, for 34% of participants the premium is between 6% and 10%, and for 12% of participants the premium is 5% or less.

12% 47% 34% 7% More than 20% premium 11% to 20% 6% to 10% 5% or less premium

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The limited utilization of the fiscal space for pension accrual is a broader issue for participants in defined contribution schemes. On average, the pension scheme utilizes 42% of the fiscal space for the 1.8 million participants in defined contribution schemes. In the context of the new pension system with a maximum flat premium of 30%, a utilization of 42% would be equivalent to a flat premium of just under 13%. As indicated earlier, this image will change when more benefit agreements are transferred to the new system; we will update these statistics then.

How much pension do different flat premium percentages ultimately yield? To get a feel for the influence on the pension income, we have included an indication in Figure 2.

In this simplified estimate, we assume that a flat premium of 30% of the pension base at an interest rate of 1.5% leads to a pension of 75% of the average wage. We make this assumption because the interest rate of 1.5% was the basis for the maximum flat premium scale of 30%, which is intended to yield a comparable pension as an average wage scheme with an annual accrual percentage of 1.875%. Over the entire career, that average wage scheme results in a pension of 75% of the average wage (including AOW). This is generally considered sufficient, as expenses and taxes are lower after retirement than during working life.

The height of the interest rate has a large influence on the height of the expected pension. As an example, we highlight a flat premium of 10% of the pension base, which we see in Figure 1 is common. This premium level results in the example at a calculation interest rate of 1.5% in a pension of 46% of the average wage. But at an interest rate of 3% - closer to the current interest level - that rises significantly to 58% of the average wage. But at a premium level of 5%, the pension scheme in the example also results in the more positive scenario with 3% calculation interest, but in a pension of 45% of the average wage, which then consists of more than two-thirds AOW.

Figure 2: Estimate of the replacement ratio at different flat premium percentages

What does Figure 2 show? The graph gives an indication of the replacement ratio at different flat premiums and interest levels. The light blue line shows the AOW of €19,172, which at an assumed average wage of €50,000 provides a replacement ratio of 32%. The dark purple line shows the replacement ratio at different premium percentages at an interest rate of 1.5%, and the light purple shows the same at an interest rate of 3%. We assumed that the replacement ratio at 30% premium and 1.5% interest is equal to 75% of the average wage. At a lower premium, the replacement ratio decreases linearly to the AOW level of 32%.

The AFM sees the risk that participants with low pension accrual think that the supplementary pension via their employer is well arranged, while the accrual is limited.

Therefore, we call on the sector to ensure that participants have realistic expectations of their pension scheme, for example in our report from 2023. This can be done in several ways, for example by informing participants well. Participants can then take any measures in time to prevent financial problems after retirement.

0% 5% 10% 15% 20% 25% 30% 0% 30% 45% 60% 75% At 3% interest At 1.5% interest AOW Percentage of the average wage Premium percentage

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1.2 The group of employees building up pension has grown due to the reduction in the starting age

From January 1, 2024, the minimum starting age for pension accrual in the Netherlands was reduced from 21 to 18 years. As part of the Pension Agreement, the government, social partners, and the pension sector agreed to strive for halving the white spot (employees in wage employment who do not participate in a pension scheme) from 936,000 in 2019 to 468,000 in 2027. Part of this is the reduction in the starting age for pension accrual, which ensures that young people start building up pension earlier.

This has indeed led to an increase in the number of active participants. In general, we see that the number of active participants has been increasing for several years. In our data, in particular, the rise in the number of active participants in industry pension funds stands out between 2023 and 2024. The 43 industry pension funds had more than 286,000 active participants at the end of 2024 than at the end of 2023. Of these, 247,000 are accounted for by the ten largest industry pension funds.

Figure 3: Number of active participants (in millions)

What does Figure 3 show? The graph shows the development of the number of active participants in industry pension funds from 2022 to 2024 in relation to the total number of active participants. In 2023, the industry pension funds had a total of 5.84 million active participants; in 2024, this had risen to 6.12 million. The increase amounts to 286,000 participants.

1.3 For an increasing number of participants, partner pension and premium continuation in case of disability are insured

For an increasingly large part of the participants in premium agreements, there is coverage in the event of death before the pension date or in case of disability. Between the end of 2022 and the end of 2024, the share of active registrations (one participant can have multiple pensions or registrations) without partner pension coverage was halved. The group of participants without coverage for the continuation of pension accrual in case of disability (PVI) is also much smaller in 2024 than in 2022.

The AFM welcomes this development and calls for proactive information to participants for whom risk coverage does not apply. Both to prevent disappointments and to enable them to take out other insurance in time to protect against a drop in household income in the event of death or a pension gap in the event of disability.

8,20 5,59 1,85 5,84 2,02 6,12 2,08 7,45 7,86 Industry Pension Funds Other Pension Administrators

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Figure 4: Risk coverage of active participants within premium agreements

What does Figure 4 show? The graph shows per reporting year (2022–2024) the share of active participants without risk coverage, split by the lack of partner pension coverage and the lack of PVI coverage. The share of participants without partner pension coverage decreased from 19% in 2022 to 15% in 2023 and 9% in 2024. The share of participants without PVI coverage decreased from 17% in 2022 to 15% in 2023 and 12% in 2024.

1.4 However, data on the new system also shows that partner pension coverage can vary significantly

Partner pension coverage varies strongly per pension scheme in the new system. The reporting data from 2024 provides a first image of the height of the partner pension coverage agreed upon by social partners within the pension schemes in the new system. Only for a small part of the active participants is the coverage close to the maximum.

For the majority of participants, the coverage is lower than 30% of the pensionable salary, and for a small part, the coverage is even lower than 20% of the pensionable salary. With such low coverage, the household income can drop significantly in the event of death before the pension date. If participants are well aware of this, they can make other provisions.

Figure 5: Share of active participants per category of partner pension coverage relative to pensionable salary

What does Figure 5 show? The graph shows the distribution of participants in the new system by the height of the partner pension coverage in their pension scheme, expressed as a percentage of the pensionable salary. For 18% of participants, the coverage is 41% or more, for 23% of participants the coverage is between 31% and 40%, for 49% of participants the coverage is between 21% and 30%, and for 10% of participants the coverage is 20% or less.

2022 2023 2024 19% 17% 15% 15% 9% 12% No partner pension coverage No PVI coverage 10% 23% 49% 18% 20% or less 21% to 30% 31% to 40% 41% to 50% Partner pension coverage relative to pensionable salary

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Good information about risks in the new partner pension With the introduction of the new pension system, the design of the survivor's pension changes. In the event of death before the pension date, the partner pension will from now on be arranged on a risk basis by default, with a maximum benefit of 50% of the pensionable salary. Because the new survivor's pension is on a risk basis, the coverage stops if the participant leaves service and no longer participates in the pension scheme, after the expiration of the mandatory run-off coverage and any optional continuation.

With the changes that take place through the Wtp (Pension Act) in the survivor's pension, new risks and communication challenges also arise. During the transition to the new pension system, participants can, for example, become uninsured unintentionally. On our website, we have included a number of situations where you need to be extra alert to timely and clear communication, to provide participants with sufficient perspective for action in these situations.

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2. Complaint data provides a valuable perspective on the quality of service

2.1 The number of registered complaints varies by type of pension administrator

Pension funds register relatively more complaints per participant than PPIs. In absolute numbers, no less than 99% of all complaints in 2024 came from participants of pension funds, compared to only 1% from PPIs.2 Within pension funds, occupational pension funds report the most complaints per participant, and industry pension funds report the fewest. Since the new legal requirements for adequate handling of complaints have been in force since July 1, 2023, 2024 is the first full year for which the AFM has data on complaints at pension funds and PPIs.

Figure 6: Average number of registered complaints per 10,000 participants

What does Figure 6 show? The graphs show the average number of registered complaints per 10,000 participants, split by type of pension administrator (pension fund or PPI, left) and type of pension fund (occupational, enterprise, general, or industry pension fund, left). We have related the number of complaints to the number of active participants (dark purple) and the total number of participants (light purple).

A low number of registered complaints is not automatically positive. A high number of complaints can indicate problems in service delivery. This could, for example, concern experienced shortcomings in the quality of service, compliance with rules, or interaction with participants. But a low number of complaints can also be a signal that something is not right. Participants may not know well how to submit a complaint or experience barriers to doing so (see also: Towards a complaint procedure without barriers).

It is important that all expressions that fall within the legal definition of a complaint are registered as such. Participants have the right to treatment via the complaint procedure. And to subsequently go to the dispute settlement body if their complaint (partially) is rejected.

2 For pension insurers, this part of the report is not mandatory. They already report annually on complaints to the AFM via the Complaint Survey Insurers. The data from insurers who did report on complaints is not included in this Sector in Focus, as this would otherwise give an incomplete image.

PPI Per 10,000 active Per 10,000 participants Pension Fund 93 82 47 29 43 22 12 10 Occupational pf. Enterprise pf. General pf. Industry pf. 33 3 12 1

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2.2 Most registered complaints concern pension calculation and payment

In 2024, pension funds and PPIs registered a total of more than 23,000 complaints. The complaints are classified into one of a total of twelve categories as included in the code of conduct 'Good Handling of Complaints' of the Pension Federation. Most complaints concerned pension calculation and payment, the financial situation of the fund (such as reductions, non-indexation, and investment policy), and information provision. Together, these three categories account for almost two-thirds of all complaints.

Figure 7: Number of reported and handled complaints (in thousands)

What does Figure 7 show? The graphs show the three most common categories of the 23,000 reported complaints (left) and the different outcomes assigned to the 22,000 handled complaints (right). Complaints can relate to multiple categories; for example, an error in pension calculation often goes hand in hand with incorrect information to participants. In the graph, the main category of the complaint is included, as filled in by the pension administrator.

Approximately 60% of the complaints (13,000) were rejected.

Complaints about handling time and the participant portal are often assigned. When a pension administrator offers a participant portal, the AFM calls for ensuring that it functions well, especially if the portal forms the basis for interaction with participants. Poorly functioning portals can lead to confusion, incorrect or incomplete information, or missing choice moments. In general views...