Report · AFM · 2 Nov 2026
The AFM's compliance research among seven pension administrators found statutory shortcomings in survivor's pension information at one or more life events. Pension providers must personally alert participants to digital information, state the basis and coverage percentage in start information, and explicitly and repeatedly point out partner registration in defined partner systems. Survivors must receive full insight into the amount, start date and development of their pension. Providers must actively trace all entitled survivors, including stepchildren and foster children, and must assess schemes for situations where participants are unconsciously uninsured and adjust them where possible.
In short A survivor's pension protects survivors against an unexpected loss of income upon the death of the participant. Clear information and insight into choices during various life events gives the participant support and scope for action. In its research, the AFM finds that pension administrators pay a great deal of attention to survivor's pension, but also that the provision of information about it still falls short. The AFM calls on pension administrators to take note of the findings in this report and apply them to their own provision of information.
Do I get a partner pension and how much is that?
If I do not continue my survivor's pension, will my survivors get nothing at all if I die?
Will my partner and children get a survivor's pension?
Do I need to take action for that?
ANALYSIS
REPORT
NOVEMBER | 2026
Survivors are inherently vulnerable. Distressing situations must be prevented as much as possible. In addition to the loss of their loved one, survivors may also lose part of their income. A survivor's pension is intended to limit an unexpected loss of income for a partner or child, at a very vulnerable moment in their lives. It is therefore important that participants1 and their survivors have a good picture of the amount of the survivor's pension and the conditions that apply to it. Participants can then take timely action where necessary so that their partner and children are not confronted with painful surprises. After all, upon death there is hardly any scope for action for the survivor, and they may be confronted with adverse financial consequences during an already vulnerable period.
Survivor's pension is a complex subject. To ensure that the survivor's pension is properly arranged, it is important that participants are explained in an understandable way how the survivor's pension works. The exact design of the survivor's pension depends on various factors. Who is entitled to it, how high is the payment to survivors, in which cases is a participant insured or not, and when must the participant or survivor take action? In this report, we discuss the importance of good provision of information, but also situations in which participants are often unwittingly and undesirably not insured for survivor's pension. Because a survivor's pension ultimately revolves around protecting a vulnerable group of people, we introduce several personas that make the risks concrete and tangible (see Figure 1). In addition, a list of the most common terms with explanations is included on page 6.
The survivor's pension has been fundamentally changed in various respects by the Future of Pensions Act, with the aim of making it more uniform and thereby clearer for the participant. The partner and orphan's pension that a survivor receives upon the death of the participant before the pension date is henceforth on a risk basis for all pension schemes. The amount of the partner and orphan's pension before the pension date is a percentage of the pensionable salary in all pension schemes and is no longer dependent on the number of years of service. A survivor's pension on a risk basis also means that the partner and orphan's pension lapses when a participant leaves employment, unless they choose to continue it themselves.2 In addition, the definition of who is considered a partner has been harmonised (the partner definition). It is therefore important that a participant and their survivors understand what the survivor's pension entails and what the consequences of this are for their personal situation. In Appendix 1 you will find an extensive description of the main changes.
Pension administrators can offer participants and their survivors support and scope for action by carefully arranging the survivor's pension and clearly informing them about it. Pension administrators must therefore, by law, at least provide information about the survivor's pension to participants and survivors (partner and child) upon entry into service, exit from service and commencement of the pension.3 At each of these events, the emphasis is on a different information need, and therefore different
[1] By participants we mean active members, former members and pensioners.
[2] After exit from service, the participant is still covered for the survivor's pension during the run-off period or in the event of entitlement to an Unemployment Act or Sickness Act benefit.
[3] Article 21 Pw, article 39 Pw and article 43 Pw.
ANALYSIS
REPORT
elements must be included in the provision of information. As a follow-up to a previous exploration4 of the survivor's pension, the AFM has conducted a compliance research5 among seven pension administrators (pension funds, insurers and PPIs) that implement schemes in the new pension system. In this research, we looked at the design of the survivor's pension and how pension administrators communicate about it with participants and survivors during various life events. We have tested the information received from the parties examined against the statutory obligations6 in Appendix 2. In this research, the AFM did not assess whether the choice guidance requirements7 were met for choices relating to the survivor's pension. We did, however, look at which communication messages contain information that is relevant to prompting action and must therefore be shared with a participant in advance of the choice process.
The AFM sees that pension administrators pay attention to the survivor's pension and make efforts to arrange it carefully. At the same time, our research shows that all pension administrators examined have statutory shortcomings in the provision of information during one or more life events. Information must reach the participant or survivor in a timely manner and be tailored to the specific situation of the participant or survivor. The information must be focused on what is relevant to the participant or survivor at that time and prompt them to take action. The AFM calls on the sector to take note of the findings below and to implement them in the provision of information to participants and survivors.
Prompt your participants to take action. This starts with clearly and correctly stating the amount of the survivor's pension in the first tier of the start information, and making an explicit call to participants to check whether that is sufficient. The start information does not have to contain personal amounts, but it must be clear to the participant how the partner and orphan's pension is calculated in order to determine whether it is sufficient for them. It is important that this call is not made only once at the start of participation in the pension scheme, because the family situation and the employment choices made by the participant can change the financial situation. The financial impact of death means that information about the amount of the survivor's pension deserves a prominent place in participant communications. At the start of participation, this must not only be found in the pension regulations, as we saw several times in our research. This increases the chance that participants will know whether they want to continue the coverage for the survivor's pension themselves when they leave employment. For schemes in which the partner's pension is only paid out if the partner has been registered in advance (a defined partner system), we expect pension administrators to point this out to participants explicitly and repeatedly.
Provide survivors with full insight into their survivor's pension. Survivors usually do not have access to the deceased participant's pension portal, nor can they look up information about the pension scheme there. Our research shows that it is not always clear when survivors receive their first payment and whether any back payments will follow. It is also often not immediately clear what impact a variable or fixed payment can have on the amount of a survivor's pension in the long term. Include survivors in how much pension they receive, when they receive it, and how this develops. These are mandatory components of the provision of information.
[4] In 2025, the AFM shared various risks and points of attention sector-wide regarding the survivor's pension in the new system. See webpage Survivor's pension.
[5] In a compliance investigation, the AFM assesses whether the relevant statutory articles are being complied with. If this is not the case, the AFM will in principle proceed to impose an appropriate measure.
[6] In this report, the AFM names the articles from the Pension Act (Pw) and the Decree implementing the Pension Act and the Act on mandatory occupational pension schemes (BuPw). Where an article from the Pw is mentioned in this report, the corresponding article from the Act on mandatory occupational pension schemes must also be read there.
[7] Article 48a Pw. For this, we refer to the information on the webpage Choice guidance.
ANALYSIS
REPORT
Ensure that the surviving dependants' pension reaches all entitled persons. The AFM expects pension providers to actively make efforts to trace all entitled surviving dependants. The research shows that the start information does not always make clear who falls under the partner or child definition, while this information is important to register partners and children who may be entitled to partner or orphan pension in a timely manner. Also after death, it must be clearly communicated who can claim a surviving dependants' benefit, so that potential entitled persons can take action. This is important especially in an undefined partner system, where even after death it may be demonstrated that someone is a partner because there was a shared household. Pension providers use data from the Personal Records Database (BRP), but may not be able to trace all entitled persons with it. They must therefore also direct their communication at more complex family situations in order to identify and reach all entitled (ex-)partners and orphans, including stepchildren and foster children.
Prevent situations in which participants are unconsciously not covered. Our research shows that participants in various situations can be unconsciously uninsured for the surviving dependants' pension, which may mean that surviving dependants do not receive a benefit upon death. This concerns, for example, the complete absence of partner and orphan pension in the scheme, very low coverage and when the coverage of the surviving dependants' pension ends, such as upon termination of employment or (delayed) retirement. The following applies here: if the situation can be prevented, that is often the best solution. The AFM therefore calls on pension providers to assess their schemes for such risks and, where possible, adjust them, so that distressing situations for surviving dependants are prevented. If situations cannot be prevented, then this must at least be clearly told to participants. The AFM therefore emphasises that pension providers must inform participants in a timely, clear and complete manner about these situations.
ANALYSIS
REPORT
For this research, we examined different types of participants. The illustrative personas below give an impression of the differences in information needs.
Figure 1: Different information needs
For this research, we examined different types of participants (active, former, pensioner, partner and orphan). The illustrative personas below give an impression of the differences in information needs.
Read more about this:
Dennis
36 years
Dennis has just changed jobs. He has a young family that he takes good care of to take care of. It is important for Dennis that with his starting information he can answer the following questions:
How much will my surviving dependants receive if I die?
1.2 4.1
Who is covered? Do I have to register my partner and children for that?
1.4 H3
Do I have to make choices for my surviving dependants' pension or arrange something myself?
1.2 1.5
Nadia is quitting her job at the hospital.
After a break of 3 months she will go to work in a care home. In the stop information from the pension provider she reads that she can continue her surviving dependants' pension herself. Nadia has the following questions:
Nadia
43 years
If I do not continue my surviving dependants' pension, will my surviving dependants then receive nothing at all if I die?
1.3
How much will my surviving dependants receive if I continue my surviving dependants' pension and what are the consequences of this choice?
1.3
When do I have to make a choice?
1.3 4.2
Anita
67 years
Anita has just retired. She lives together with her husband and two sons aged 23 and 28. She has already passed on her choices to her pension provider and has just received a confirmation of this. After reading this information, she has the following questions:
Has my choice for partner's pension been processed correctly?
4.5
Will my children receive pension if I die?
4.4
How much will my surviving dependants receive if I die?
4.3 4.5
Ravi lost his girlfriend a month ago.
They lived together for 5 years in a rented house, but had no cohabitation contract. From her pension provider he has received information.
Ravi hopes with this to answer the following questions:
Ravi
50 years
Will I receive partner's pension and how much is it?
2.1 2.3 H3
Do I still have to take action myself for that?
2.1 H3
From when will I receive the pension payment?
2.2
Where can I go with questions?
1.6
Sem
18 years
Sem is 18 years old and he has just lost his stepfather.
His stepfather's pension provider has sent information to the home address of his mother and stepfather. Sem wants answers to the following questions:
Will I receive a pension benefit and how much is it?
2.1 2.3 H3
Do I still need to take action myself for that?
2.1 H3
From when will I receive the pension benefit?
2.2
And when does it stop?
4.4
Where can I go with questions?
1.6
ANALYSIS
REPORT
Table 1: Glossary
The glossary below contains an explanatory list of the most commonly used terms in this research report.
| Term | Explanation |
|---|---|
| Partner concept | Who is entitled to partner pension according to the law. This is laid down in Article 1, 2a and 16 of the Pw. |
| Child concept | Who is entitled to orphan's pension according to the law. That is laid down in Article 1 and 16 of the Pw. In the Legislative Proposal Commitments Wtp and other pension topics, it is further elaborated who will be regarded as a child. |
| Orphan | A child one or both of whose parents have died. If both parents have died, the child is a full orphan. |
| Partner system | There are two types of partner systems. In both systems, a partner must meet the partner concept. Married people and registered partners are often automatically registered as partners with pension providers via the BRP. In other situations, the participant must register his partner with the pension provider. In a defined partner system, this must be done before death. In an undefined partner system, a partner can also demonstrate after the participant's death that he is entitled to a partner pension. |
| Survivor's pension on a risk basis | A participant is covered for the survivor's pension as long as he is employed, but this coverage lapses when he leaves service. |
| Basis for partner / orphan pension | The amount on which the partner or orphan pension depends. Usually this is the pensionable salary, sometimes reduced by the offset. |
| Coverage percentage partner / orphan pension | The percentage of the basis that a partner or child receives if the participant dies. This percentage differs per scheme but is capped by law. For a partner this is a maximum of 50%, for a half orphan a maximum of 20% and a full orphan a maximum of 40% of the last pensionable salary. |
| Run-out coverage | The risk coverage for the survivor's pension that continues when a participant leaves service and does not immediately have a new employment contract. |
| Run-out coverage period | The period during which the run-out coverage continues. The standard period is 3 or 6 months. The run-out coverage can be shorter when the participant has a new employment contract. |
| Automatic continuation of risk coverage | The run-out coverage or the risk coverage that continues when the former participant is entitled to an unemployment benefit or a Sickness Benefits Act benefit. This is included in Article 55 Pw. |
| Voluntary continuation | The choice of a participant to continue the survivor's pension when he has left service. The former participant finances this from his accrued capital. This is included in Article 61a Pw. |
| Equal adjustment with spreading | Method to spread the processing of (investment) results in pension benefits over several years and at the same time adjust the benefit for all pensioners by the same percentage. |
ANALYSIS
REPORT
1. Encourage your participants to take action 8
1.1 Personally alert participants to digitally provided information 8
1.2 Inform participants what they can do themselves about the level of the survivor's pension 9
1.3 Enable participants to take action upon leaving service 10
1.4 Prominently point out partner registration in schemes with a defined partner system 11
1.5 Enable participants to respond in time 11
1.6 Ensure that survivors know where they can go with questions 12
2. Offer survivors full insight into their survivor's pension 13
2.1 Make clear how high the survivor's pension is 13
2.2 Ensure that survivors know when their pension starts 14
2.3 How does the survivor's pension develop? 14
2.4 Align the tone and content of communication with the situation 14
3. Ensure that the survivor's pension reaches all beneficiaries 16
4. Prevent situations in which participants are unconsciously uninsured 19
4.1 Participants are not informed of the absence of partner and orphan's pension in the pension scheme 19
4.2 Participants are uninsured, but still have the option of voluntary continuation 19
4.3 Survivor's pension on a risk basis does not continue in the event of postponement of pension commencement 21
4.4 Unclearness about the end of coverage and payment of orphan's pension after pension commencement 22
4.5 After retirement, a partner who has not been registered has no right to partner's pension 22
Appendix 1: Background and research design 23
What has changed in the new pension scheme? 23
Appendix 2: Legal framework 25
ANALYSIS
REPORT
A survivor's pension protects the surviving dependants against an unexpected drop in income upon the death of the participant. In order to have adequate survivor's pension coverage, in some situations an action by the participant is expected. For example, a participant must make choices or provide information that have an impact on the amount or the coverage of the survivor's pension. This could include registering a partner or voluntarily continuing the survivor's pension. If the participant does not take this action (in time), this can have major consequences for the surviving dependants. That is why there are various fixed moments at which a participant receives information about the survivor's pension. This information must encourage the participant to take relevant action.
In our research we see that the digital provision of information often consists of references to information on the website or on the personal pension portal. Half of the pension providers do not state what information can be found there and why it is important that the participant takes note of this information. The AFM welcomes layering in communication. It is important, however, that a participant is encouraged by the information provided to take action. That happens to a limited extent if a participant does not know what information can be found via a link. A pension provider is obliged, when providing information via the website, to personally alert the participant to this.8 General announcements that a message is ready do not suffice. The participant must be personally pointed out what important information is in the pension portal and why it is important to view this information. Do that with a direct link, so that the participant does not have to search in the portal themselves to find this information. This increases the chance that a participant takes note of the information and takes follow-up actions.
For participants who have explicitly indicated that they wish to receive their information in writing, pension providers must provide all information on paper. This too may be layered, for example by means of attachments. When using layering, it is important that the information is correct, clear and balanced both as a whole and per layer. When information that must be provided is provided via the website, it must be on the participant's personal pension portal and not via the general website.
Point of attention: No personal alert about survivor's pension information in the start letter. In the start letter of one of the pension providers, the only thing stated about the partner's pension is: “Tip: also check what your registration means for your pension. You can read more about this on our website under “In service”.”
Good example: start information about the survivor's pension that encourages action. A pension provider adds Layer 1 of the old pension 123 as an attachment in the letter: “You will find Layer 1 with this letter. Here you can read what choices you have. And when you need to take action.” This attachment states, among other things: “If you have a cohabitation contract or a cohabitation declaration. Then register your partner with us.”
[8] Article 49, paragraph 2, Pw.
ANALYSIS
REPORT
The coverage for the partner and orphan's pension will not be sufficient for every participant. There is no statutory minimum for the amount of a survivor's pension, which means that the coverage for the partner and orphan's pension can vary greatly between pension schemes. Both the coverage percentage and employment choices that have an effect on the salary can cause the survivor's pension to be insufficient to cover the household's expenditure pattern.
A pension provider must therefore provide the basis and the coverage percentage of the partner and orphan's pension in the start information.9 This information shows that the survivor's pension depends on the salary, and enables the participant to assess for their own situation whether it is sufficient or whether they may need to arrange something additional. Depending on the situation, the participant can mitigate this risk by:
Voluntarily supplementing the partner's pension within the pension scheme, or arranging something outside the pension scheme (for example by taking out a death risk insurance);
Taking out a survivor's bridging pension/ANW pension;
Opting for voluntary continuation of the survivor's pension upon termination of employment.
The options that are possible within the current scheme must be provided to participants via the start information.10 In addition, pension providers can help participants by pointing out the other options to them, such as a death risk insurance, and making them aware of the effect of employment choices on the survivor's pension.
[9] Article 21 Pw
[10] Article 2 BuPw
Will my partner and children receive survivor's pension? Do I have to take action for that?
Dennis, 36 years old
Dennis has just changed jobs. He has a young family that he wants to take good care of.
Different pension scheme
At his new employer, the pension scheme provides a partner's pension on a risk basis.
15%
Salary €50,000
€7,500
50%
€25,000
Salary €50,000
New employer
Partner's pension: 15% of his salary. Upon his death, his partner receives €7,500 partner's pension per year for life.
Previous employer
The same salary, but a different partner's pension: 50% of his salary, in other words €25,000 partner's pension per year.
Leaving service
1 Jan '26
Receipt stop letter
1 Mar '26
End run-off coverage
1 Apr '26
Death
10 Apr '26
Choice voluntary continuation
1 May '26
Run-off coverage
Choice period
If I do not continue my survivors' pension, will my survivors then receive nothing at all if I die?
Nadia, 43 years old
Nadia stops her job at the hospital. After a break of 3 months she will work in a care home.
Various situations can arise in which Nadia is only presented with the choice for voluntary continuation of the survivors' pension after the mandatory run-off coverage has already ended. This can lead to the unfortunate situation that Nadia dies precisely in the period in which she was still entitled to a choice to continue the coverage, but is uninsured according to her pension scheme. That can put her partner and children in a financially vulnerable situation . Pension providers (and social partners) must be aware of these situations and try to prevent them where possible, for example through the design of their execution, timely communication or policy. Voluntary continuation The new coverage is not sufficient for their spending pattern and therefore Dennis and his partner decide that they need to arrange something extra. Clear communication about this in the start information offers Dennis and his partner a course of action.
ANALYSIS
REPORT
In addition to newly entering participants, pension providers can also help surviving dependants to supplement their pension themselves. In the situation where the participant has died, there is the possibility for low incomes to supplement this via, for example, the ANW pension from the government or benefits.11 Pension providers do not have to point this out to surviving dependants, but they can offer them a course of action in this regard.
Good example: Informing surviving dependants about supplementing survivor's pension at low income Some pension providers actively mention in the communication to surviving dependants the possibility for low incomes to supplement a survivor's pension via, for example, the ANW pension from the government or benefits and also refer specifically to the Sociale Verzekeringsbank or the Belastingdienst for more information
It is important that a participant knows that the coverage ends when he leaves employment. In most cases, a participant can opt for voluntary continuation of the coverage of the survivor's pension. But only present this choice if the participant can actually choose it. If the old-age pension is below the commutation threshold, for example, this is not possible. Then explain to the participant why he cannot make this choice.12 Participants who can opt for voluntary continuation must be pointed this out and receive information about it, including the level of coverage and the response period.
In addition, the participant must be pointed out the consequences of choosing or not choosing voluntary continuation.13 For example, the participant finances the continuation from the old-age pension, so that the old-age pension becomes increasingly lower as the continuation lasts longer. The participant must also know when the voluntary continuation expires. Once the old-age pension falls below the commutation threshold, the coverage is automatically terminated. The participant can always choose to stop the coverage. The pension provider must point this out to him annually. The pension provider may also impose a maximum on the duration or scope of the voluntary continuation, as long as the pension provider facilitates this for at least fifteen years.14 If the participant does not choose to continue voluntarily, he must be pointed out that there is then no coverage for survivor's pension from that pension scheme.
There may also be a part of survivor's pension on an accrual basis or restitution that still originates from the pre-Wtp scheme. This accrued survivor's pension does not lapse upon termination of employment, so the participant may not need a voluntary continuation of the risk coverage. Therefore communicate about these two different coverages and what they entail, so that the participant can assess whether it is necessary to continue the risk coverage. In our research we saw that not all pension providers make this breakdown clear in the stop information.
Pension providers must make clear to participants who leave employment how long the run-out coverage period is and how high the coverage is during this period.15 All pension providers in our research inform participants about the lapse of the survivor's pension on a risk basis. But information about the coverage during the run-out period often falls short, because this information often comes too late or is not included in the stop information. The participant must receive this information within the standard term of the run-out coverage (3
[11] https://www.svb.nl/nl/anw
[12] Article 10bb, paragraph 2, sub a, BuPw
[13] Article 10bb, paragraph 2, sub d, BuPw
[14] Article 61a, paragraph 2, sub b, Pw
[15] Article 6, sub g, BuPw
ANALYSIS
REPORT
or 6 months), because otherwise this information is no longer relevant and timely. As a result, a participant unconsciously runs the risk that his surviving dependants will not receive a pension upon his death.
Point of attention: incorrect information regarding run-out coverage in stop letter A pension provider mentions the presence of the run-out coverage in the stop letter, even if the stop letter is only sent after the standard term of 3 months for the run-out coverage has already expired. The pension provider does not mention that the coverage has already ended. This information is then no longer correct. The AFM expects that participants receive this information in a timely manner, so that a participant knows when his coverage stops and can take action on that basis.
In the case of a defined partner system, it is important that the participant registers his partner, to prevent the surviving dependant from ending up in a distressing situation afterwards. In this partner system, the participant's partner only receives a pension payment if that person is registered with the pension provider before the participant has died. They do not have the possibility, as in an undefined partner system, to demonstrate after the participant's death that there was a partner relationship.
We see in our research that pension providers with a defined partner system do not always clearly prompt participants to take action. A reference to more information in the pension scheme is not enough. The conditions for the partner's pension must be clear to participants. The pension provider must promote that the information about this prompts the participant to take relevant action, namely
registering the partner. This must be done both in the start letter and in recurring communication such as the UPO.
It is important that the pension provider makes every effort to point out to the participant the obligation to register the partner, and what the consequences are if the participant does not do so. For example, send a reminder if participants do not respond to the call. Or use communication at certain life events, for example if the participant reports a move. After all, the consequences for an unregistered partner are significant
Point of attention: providers with a certain partner system do not always clearly prompt participants to take action. A pension provider has included the following in the start information: “If you live together, you must meet certain conditions. There are conditions that determine when we do not pay out. You can read more about this in the pension scheme.” This does not sufficiently prompt action to still register the partner.
As a pension provider, help the participant to make the necessary decisions for their pension in time. This is important for the choice of whether or not to voluntarily continue the survivor's pension and for providing relevant data before the commencement of partner's or orphan's pension, such as proving that someone is a partner, the account number and choice for payroll tax credit. To make choices, a pension provider must at least send the necessary information in time and inform the participant about the response period. It must give the participant insight into the consequences of not responding in time.16 This can help the participant take action. What if the participant does not respond? Then send a reminder in time. Using different channels, such as an
[16] Article 48, paragraphs 3 and 4, Pw
ANALYSIS
REPORT
e-mail and a letter by post, can increase the chance that the participant takes action.
Prevent survivors from wrongly thinking that they are no longer entitled. During the investigation, the AFM found that pension providers sometimes include a response period in application forms to motivate participants to respond in time. Encouraging action is good, but this can also lead a participant whose response period has expired to think they are no longer eligible for a survivor's pension, even though that right has continued to exist. Therefore, pay close attention to the wording.
Survivors often first come into contact with the pension provider of the deceased after the death. This is a difficult period for survivors, in which, in addition to missing their loved one, they also have to arrange many practical matters. As a pension provider, therefore ensure that survivors are relieved of burdens. Not only with careful communication towards the survivor, but also by actively calling on the survivor to contact the provider with questions or if they need more information.
Good example: personal contact with survivors. Various pension providers offer personal guidance to survivors upon the death of a participant. For example, some survivors are each assigned a personal counselor, or there is a survivor desk where participants can turn to specialists trained in guiding people through the difficult time following the death of a loved one.
ANALYSIS
REPORT
For survivors, it is important that they receive clear and complete information about the survivor's pension. If a participant dies, their partner and children receive information from the pension provider about their partner's or orphan's pension. This may be the first time they receive information about the survivor's pension. They usually do not have access to the pension portal of the deceased participant, and cannot look up information about the pension scheme there either. Therefore, guide them through how much pension they receive, when they receive it and how it develops.
For clear communication towards survivors, it is important to always communicate euro amounts. This makes it clear at a glance what the survivor is entitled to and what pension they will receive. The amount of the (net) pension benefit can also be influenced by applying payroll tax credit or if the orphan has lost both parents (is a full orphan). To ensure that the amount of the survivor's pension is correct, the pension provider must also provide good information about this. All pension providers in our study include the amount in euro amounts in communication around pension commencement, but information about payroll tax credit and the full orphan is missing in some.17
At the moment that the second parent of an orphan dies (or has already died), many pension schemes stipulate that the full orphan is entitled to a doubling of the orphan's pension. To determine the amount of the pension benefit, the pension provider must establish whether there is a full orphan or not. From our
study it appeared that pension providers cannot always establish whether there is another parent. In that case, the full orphan (or their legal representative) must report this to the pension provider themselves. It is therefore essential to include the right to a full orphan's pension in the communication towards the orphan. Full orphans belong to a very vulnerable group and it is therefore important that they are aware of the fact that they can claim the higher benefit if they meet the conditions. In doing so, it is of course important to convey this message in an appropriate way.
Whether or not payroll tax credit is applied affects the amount of the benefit for a survivor. This is a choice that the survivor must pass on to the pension provider, with potentially far-reaching consequences. In the case of double application of the payroll tax credit, the surviving dependant will receive a high additional assessment at the end of the year, which can lead to distressing situations, especially for lower incomes. Therefore, inform participants in advance about the operation and rules of the payroll tax credit and confirm the choice made in the award letter.
Good example: information about double orphan's pension included in the award letter The guardian of the orphan receives the following notice: “If you are not the parent of x and both parents are no longer alive, then there may be entitlement to a double orphan's pen- sion. If this is the case, please notify us as soon as possible .” This reduces the chance that a full orphan receives a too low benefit.
[17] Article 43 Pw
ANALYSIS
REPORT
The surviving dependant needs clarity about the commencement date of the benefit. It is not inconceivable that there may be one or more month(s) between the commencement date and the actual payment, because a participant may die later in the month and correspondence is sent back and forth. In our research, we see that pension providers deal in different ways with information in the award letter at the commencement of the surviving dependants' pension. Partners and orphans are not always informed when they will receive the first payment exactly and whether there are back payments. Therefore, always communicate in the award letter for surviving dependants when they will receive the pension and how any back payments will be handled. This information is important at pension commencement so that a surviving dependant knows where he stands and must therefore be provided.18
For the future benefit amount, it is important to know whether the surviving dependants' pension concerns a fixed or variable benefit. If there is a variable benefit, then it is relevant to know when the pension provider determines the adjustment, how he determines it and as of when he implements the adjustment. The AFM notes that not all pension providers explain this in the communication to surviving dependants.
Pay attention to the impact for the surviving dependant in the long term. The partner's pension is for life. In addition to (partially) bridging the income gap in the short term, it will also be an important part of a surviving dependant's finances for the long term. This is especially relevant for partners who receive partner's pension at a relatively young age due to the premature death of the participant. A surviving dependant has a lot on his mind at the time of death, so he may not be aware of the impact that a fixed or variable pension has in the long term.
Therefore, also consider in the award letter the consequences of a fixed/variable pension. In the case of a variable pension, inform about the operation and annual adjustment of the amount.19 At the same time, remain balanced about the trade-off between risk and return and that a variable pension is also not expected to fully preserve purchasing power. For more information about information provision for a variable pension, also see this previously published report by the AFM. The AFM considers it desirable to mention in the case of a fixed pension the impact of inflation and the associated loss of purchasing power.
Pension providers have additional communication obligations if they use equal adjustments with spreading in the payout phase.20 The pension provider must provide the mandatory information prior to or at pension commencement. This also applies to a surviving dependant when equal adjustments with spreading are applied to his pension benefit. The AFM notes that in almost all investigated parties where there is a collective payout phase with equal adjustments with spreading, legally required information for participants is missing.
In our research, we see in the contact with the surviving dependant that the personal situation is generally well taken into account. In the first contact, for example, it is already clearly explained what has been arranged for the surviving dependants, what the process up to payment looks like, what the surviving dependant can expect in it and what the surviving dependant still needs to pass on. In addition, there were letters to
[18] Article 43 Pw
[19] Article 43 Pw
[20] Article 7a BuPw
ANALYSIS
REPORT
the surviving dependants in which the tone and content were less appropriate to the situation of the surviving dependant. For example, the surviving partner had to provide information about earlier divorces of the deceased participant and the letters contained texts that did not apply to the current partner. Ensure that only missing information is requested that a surviving dependant logically has at his disposal and that the information aligns with the situation of the surviving dependant.21 For example, by using information already known to the pension provider about the surviving dependant or information available via the BRP. This promotes that the information lands better.
A pension provider communicates the following to the partner: “You do not need to pass anything on to us now. In this difficult time, you probably already have a lot to arrange. But not with us for now. If you are entitled to partner's pension, you will receive a letter from us within 2 weeks”. The partner therefore knows what he can expect and when he should or should not take action.
[21] Article 48, paragraph 2, Pw.
ANALYSIS
REPORT
The AFM expects pension providers to make maximum efforts to trace all entitled surviving dependants. A pension provider must provide all pension beneficiaries with information at pension commencement and must therefore know who the entitled persons are. We see that pension providers deal in different ways with identifying the entitled surviving dependants when a participant has died. In the case of an undefined partner system, it can be a challenge to ensure that all entitled surviving dependants have been traced and receive a benefit. It is therefore essential that pension providers communicate at various moments about who is entitled to partner's pension and encourage participants in this communication to take action to register a possible partner.
In the study, we see that it is not always clear from the start information who falls under the partner definition. This is relevant information for the participant to register the partner and is therefore mandatory. Especially in the case of a defined partner system, it is essential that the pension provider explicitly and frequently points this out to participants. Make sure that the participant knows that this does not only mean registered partners and spouses. A cohabiting partner, such as a brother or other housemate, can also be registered as a partner and may be entitled to partner's pension if the participant dies.
Will I receive partner's pension and how much is it?
Ravi, 50 years old
Ravi lost his girlfriend a month ago. They had already been living together for 5 years in a rented house, but had no cohabitation contract.
Ravi was not registered by his partner with the pension scheme and must subsequently demonstrate that he is a partner. The pension provider does not know of Ravi's existence, but did send a general letter to the home address. It is important that it shows what Ravi must do to claim the partner's pension, because otherwise he may miss out on his benefit.
This is what Ravi must do to claim the partner's pension
ANALYSIS
REPORT
Also for the orphan's pension, we see that in the start information it is unclear who falls under the child definition22, sometimes this information is even completely missing. Pension providers generally do not register children before the death of the participant. In addition, it may not be possible to find all children who fall under the child definition, including stepchildren and foster children, via the BRP. In that case, pension providers depend on registration by the (ex-)partner or the child itself. Clarity about who is entitled to the orphan's pension can prevent entitled children from being missed.
In the case of different partner or child definitions, it is extra important to make clear to the participant who is entitled to which benefit in the event of death. This may be the case if respected rights from the old system have a different partner or child definition than the Wtp scheme. For example, it may occur that a cohabiting partner can claim the partner's pension on a risk basis, but not the respected partner's pension on an accrual basis.23 Clear communication prevents unintended misunderstandings from arising, for example because a partner or orphan falls under the new but not the old definition or vice versa.
Enable the surviving dependant to check whether he may be entitled. The AFM expects that in the absence of a registered partner, the partner definition is included in the communication that is sent to the heirs or the home address after the death of the participant. In addition, communication to known (ex-)partners can also be used to trace entitled children.
[22] The uniformisation of the child definition is included at the time of publication of this report in the Wetsvoorstel toezeggingen Wtp en andere pensioenonderwerpen
[23] Article 220g Pw
Pension provider
BRP
Will I receive a pension benefit?
Sem
Sem, 18 years old
Sem has just lost his stepfather.
His stepfather's pension provider has sent him information.
Although Sem's mother has been together with Sem's stepfather for 15 years, Sem is not registered in the Basisregistratie Persoonsgegevens (BRP) as a child of his stepfather. Because Sem is of age, he must register himself with the pension provider.
The pension provider must therefore make extra effort to reach and ensure that he receives a benefit.
ANALYSIS
REPORT
ANALYSIS
REPORT
In addition to clarity in the communication about who qualifies for a survivor's pension, there are other ways to trace all beneficiaries:
Various beneficiaries can be traced via the BRP, such as legal children and married or registered partners;
Communicate directly with beneficiary children and not via information to the (known) partner. Focus your communication here on complex family situations, often due to divorce. For example, there are sometimes children who no longer have contact with a parent, children abroad, or stepchildren and foster children.
In the communication to the partner, also include general information about the orphan's pension, such as which children may qualify for it.
The letter to partners and orphans is highly personalised. There are different types of letters for this. If all information is already known, then the partner needs to fill in very little.
A pension provider requests information from the current partner about any ex-partners of the deceased participant. A current partner can be used to help obtain information about beneficiaries, but is not responsible for it.
The start information states that someone is a partner if you marry, enter into a registered partnership or share a joint household. It is not explained what is meant by a joint household. Make clear who falls under the joint household, so that it is clear to participants who is entitled to partner's pension.
Our research reveals a number of situations in which participants, without being aware of it, are not covered for survivor's pension upon death. To prevent distressing situations, it is very important that participants know if nothing has been arranged for survivors. The participant can then take action on this themselves. Pension providers have the responsibility to communicate clearly about this and to point out these situations to participants. Some of these situations can be prevented by adjusting the pension scheme. We explain a number of situations, and call on pension providers to assess whether these and possibly other situations occur at their organisation.
It can occur that a pension scheme does not include coverage for survivor's pension in the accrual phase. In 2025 this applied to 9% of the 2.1 million active participants in premium schemes.24 Pension providers must explicitly point this out to participants in the start information.25 In that way participants can assess whether they want to arrange something themselves for the survivor's pension, possibly within the scheme and otherwise outside it (for example by taking out a death risk insurance).
In our research we have seen that participants are only presented with the choice for voluntary continuation of the partner's pension once they are no longer in the run-off coverage period. Or that the response period for the choice continues longer than the end of the run-off coverage. For example, a participant may only have received the information about the voluntary continuation choice (usually via the stop letter) after the end of the run-off coverage period. This can happen because the participant has already entered into a new employment relationship (where there may be no survivor's pension) or because the termination of employment is only reported later by the employer or processed later in the pension provider's administration. Also, the stop letter is now sometimes only sent after the run-off coverage period has already expired. Another possible situation is a lack of insight from the UWV into the end of the right to risk coverage in connection with a WW or Sickness Benefits Act benefit. In these situations, participants who have been pointed out have no coverage for the partner's and orphan's pension, but still have the right to choose voluntary continuation.26 Although some situations may be outside the pension provider's control, it is important that pension providers are aware of these situations and formulate policy to deal with them.
[24] See for this the report Sector in beeld pensioenen 2026
[25] Article 21 Pw and Article 2, opening words and sub b, BuPw.
[26] Article 61a, first paragraph, Pw
ANALYSIS
REPORT
ANALYSIS
REPORT
Upon receiving the stop information, a participant has already left service. Therefore, the start information must also already point out what the survivor's pension on a risk basis entails and the choice for voluntary continuation of the survivor's pension.27 The participant is then aware that his survivors will not receive a survivor's pension if he leaves service and dies, unless he takes action himself.
Discussions are currently being held about a sector-wide approach for dealing with situations in which a participant is not covered, but does have the right to choose voluntary continuation of the survivor's pension.28 At the same time, these kinds of situations can already arise now. Some of the pension providers investigated indicate that they assess this per situation, but in principle grant leniency for payment of the partner's or orphan's pension if a participant dies after the end of the run-off coverage and before the expiry of the choice period for voluntary continuation. Other pension providers indicate that the scheme rules are leading and in this case there is no coverage. We ask pension providers to map out which situations can occur with them and to think about how they can prevent these as much as possible. Think in advance about how you deal with these situations and participants if they do occur.
In pension schemes, a deliberate choice has been made for an extended coverage period of 6 months. Pension providers indicate that in this choice (by social partners), it also plays a role that they consider it important that participants remain covered even when stop letters are received late and with employers who do not report termination of employment in time. This reduces the chance of an unfavorable concurrence of the extended coverage period and the choice period for voluntary continuation of the survivor's pension.
Will my partner and children receive survivor's pension? Do I need to take action for that?
Partner's pension: 15% of his salary. Upon his death, his partner receives a lifelong €7,500 partner's pension per year.
The same salary, but a different partner's pension: 50% of his salary, or €25,000 partner's pension per year.
15%
Salary €50,000
€7,500
50%
€25,000
Salary €50,000
New employer
Previous employer
Dennis, 36 years old
Dennis has just changed jobs. He has a young family that he wants to take good care of.
At his new employer, the pension scheme provides a partner's pension on a risk basis.
The new coverage is not sufficient for their spending pattern and therefore Dennis and his partner decide that they need to arrange something extra. Clear communication about this in the start information offers Dennis and his partner a perspective for action.
Other pension scheme
If I do not continue my survivor's pension, will my survivors receive nothing at all if I die?
Nadia, 43 years old
Nadia stops her job at the hospital. After a break of 3 months she will work in a care home.
Various situations can arise in which Nadia is only presented with the choice for voluntary continuation of the survivor's pension after the mandatory extended coverage has already passed. This can lead to the unfortunate situation that Nadia dies precisely in the period in which she was still entitled to a choice to continue the coverage, but is uninsured according to her pension scheme rules. That can put her partner and children in a financially vulnerable situation.
Termination of employment
1 Jan '26
Receipt stop letter
1 Mar '26
End extended coverage
1 Apr '26
Death
10 Apr ’26
Choice voluntary continuation
1 May ‘26
Run-off coverage
Choice term
Pension providers (and social partners) must be aware of these situations and try to prevent them where possible, for example through the design of their execution, timely communication or policy.
[27] Article 21 Pw
[28] See for this the Parliamentary letter Uitwerking vrijwillige voortzetting nabestaandenpensioen of 08-06-2026
Participants may be uninsured for a survivor's pension if they retire after reaching the pension age stated in the regulations. This is the case if participants choose to postpone the pension date or if a participant has not yet purchased a pension at their regulatory pension age. This can have major consequences for the surviving dependants. In this situation, in the new system, upon the death of the participant, surviving dependants only receive a survivor's pension from the respect for existing rights or restitution of pre-Wtp accrued pension capital. If this is not present, a surviving dependant receives nothing. The risk of an income shortfall in this situation is often greater than upon termination of employment at a younger age, because the mortality risk around pension age is higher. If the partner in this scenario is also (almost) retired, he also has fewer options to absorb an unexpected income shortfall.
This can be resolved within the pension scheme, for example by continuing the coverage after reaching the regulatory pension age or by offering a choice of continuation of the survivor's pension until reaching the pension date. When choosing to postpone their pension date, near-retirees must be able to weigh whether or not there is coverage for a survivor's pension. The AFM therefore expects at least that pension providers pay explicit attention to this in the choice guidance for postponing the pension date.
Will I receive a pension benefit?
How much will my surviving dependants receive if I die?
Sem, 18 years old
Sem has just lost his stepfather.
His stepfather's pension provider has sent him information.
Anita, 67 years old
Anita has just retired. She lives together with her husband and two sons aged 23 and 28 years. She has already submitted her choices to her pension provider.
Although Sem's mother has been together with Sem's stepfather for 15 years, Sem is not registered in the Basisregistratie Persoonsgegevens (BRP) as a child of his stepfather. Because Sem is of age, he must register himself with the pension provider.
The pension provider must therefore make extra effort to reach Sem and ensure that he receives a benefit.
BRP
Sem
Anita has chosen not to postpone her pension, because in her pension scheme the coverage for the survivor's pension lapses upon reaching the regulatory pension age.
Active employment
Coverage on a risk basis No coverage
Coverage after pension date
Postponement With pension
1 Jan ‘26 1 Jan ‘28
End date Start date pension Pension provider
In the choice guidance it became clear that her husband would receive €0 in the period of postponed pension upon Anita's death. Because Anita did not postpone her pension, her partner is still covered. The difference between full coverage before and after retirement and no coverage in the period of postponed pension can be large. It is therefore important that participants can take this into account in their choice.
ANALYSIS
REPORT
Communicate with the orphan in a timely manner about the expiry of the commenced payment. The end date of the payment must be included in the communication to the orphan at the commencement of the orphan's pension and in the annual communication about the pension payment in the UPO.29 The AFM advises to inform the orphan well before reaching the final age in a separate letter about the termination of the orphan's pension.
Make explicit in the communication around pension commencement whether coverage of orphan's pension still exists during the payment phase. It is also possible that the pension scheme does not provide for orphan's pension after retirement. In the study, the AFM found that participants are not always informed about this in the communication around pension commencement. This creates the risk that participants are not aware of the ending of the coverage of the orphan's pension when they commence their pension. Therefore, state this explicitly in the communication to the participant around retirement.
Good example: orphan receives information about termination before expiry of payment A pension provider informs the orphan 3 months before the end of the payment about the termination by means of a termination notice. In it, they explain that the current payment of the orphan continues for another 3 months and will be automatically stopped on date X.
If the participant chooses partner's pension at pension date, this entitlement applies only to the partner who is registered at that moment. If the participant divorces from his partner during his retired life and enters into a new relationship, this new partner cannot claim the partner's pension. It is therefore important for pension providers to communicate clearly at retirement and during the payment phase who the beneficiary for the partner's pension is at the time of death. In addition, it is important that the pension provider clearly informs the participant at pension commencement if there is no longer any partner's pension during the payment phase.
Good example: letter to surviving dependant who receives nothing A pension provider also sends a letter upon the death of the participant to surviving dependants who do not receive a partner's pension. This situation can occur if a participant at pension date has chosen to use the capital entirely for old-age pension. Or if he has acquired a new partner after retirement. Although this is not mandatory, the AFM appreciates that the pension provider offers these surviving dependants clarity.
[29] Article 43 Pw and Article 44 in conjunction with Article 48, paragraph 5, Pw in conjunction with Article 9c BuPw.
ANALYSIS
REPORT
An important change within the new system is that survivor's pension in the accrual phase is always on a risk basis. This means that a participant is in principle no longer covered for the survivor's pension if he leaves service. The survivor's pension is also no longer dependent on the number of years of service, but on a percentage of the pensionable salary (possibly reduced by a franchise). This ensures that a participant when changing jobs does not have to suffer a disadvantage for the amount of his partner's pension due to his short period of service. The percentage may be a maximum of 50% for the partner's pension, a maximum of 20% for the orphan's pension and a maximum of 40% for full orphans.30 There is no statutory minimum for the amount of the coverage percentage for a survivor's pension. It can therefore vary greatly how much a surviving dependant receives upon the death of the participant.
When a participant leaves service and does not have a new employment contract immediately afterwards, the risk coverage for the survivor's pension continues for a period. We call this the extended coverage. This is intended to reduce the risk that someone who is between two employment contracts has no coverage for a survivor's pension. The former participant does not have to pay a premium for this. The extended coverage lasts by default 3 or 6 months, but ends earlier if the participant has a new employment contract. The risk coverage also continues as long as the participant is entitled to an unemployment benefit or a Sickness Benefits Act benefit.
After the extended coverage period or after the end of the WW or Sickness Benefits Act benefit, the participant can choose to continue the coverage for the partner's pension voluntarily. A participant has no right to this choice if there is a directly subsequent employment contract after leaving service. Pension providers must offer the choice for voluntary continuation for the partner's pension. The intention is to also make this mandatory for the orphan's pension.31 The voluntary continuation is intended to maintain the coverage. The participant pays the required premium himself from the accrued pension capital, which means the payment for the old-age pension is lower. If the old-age pension falls below the commutation threshold due to the financing of the voluntary continuation, the coverage stops. The participant can choose monthly to cancel the coverage.
The partner concept has become broader and more uniform. You are a partner of a participant if you are married, have a registered partnership or run a joint household with the participant (and can demonstrate this). This joint household includes unmarried or unregistered cohabiting partners, or another adult person with whom the participant forms a household. This may not be a blood relative in the first and second degree in the direct line, or a stepchild or foster child. This means, for example, that when a participant lives together with a brother or sister under certain conditions, they can also be a partner. Or, for example, a housemate with whom the participant is on the same rental contract. There are exceptions to the requirement to live at the same address, for example if the partner is in a care institution.
[30] Article 18b and 18c, Wage Tax Act 1964
[31] This is included in the Legislative Proposal Commitments Wtp and other pension topics. If this is adopted, the choice for voluntary continuation of the orphan's pension is also mandatory.
ANALYSIS
REPORT
In an indefinite partner system, a partner can also demonstrate after death that they fall under the partner definition. In that case, the surviving partner must be able to demonstrate that they maintained a joint household with the deceased participant. This is the case if the deceased participant and surviving partner were registered at the same address for at least 6 months, there was joint ownership of a house, both names are on the rental contract, the deceased participant was designated as a partner in the survivor's pension scheme, or there is a child born from the relationship or a recognized child.
The final age for orphan's pension is 25 years in all new pension schemes. Previously, the final age of the orphan's pension varied, depending on the pension scheme, between 18 and 30 years with conditions on age such as that the orphan was still studying or was incapacitated for work. Who falls under the definition of child is currently laid down by pension providers in the regulations. The legislative proposal Commitments Wtp and other pension topics brings change to this.
ANALYSIS
REPORT
Pension providers must provide information about survivor's pension at the various life events. The information is provided, among other things, in the start letter, stop letter and the letters at the commencement of the old-age pension, partner's pension or orphan's pension. Below, per information moment, it is stated what must be included about the survivor's pension and what the AFM's expectations are. All information that pension providers provide or make available must be correct, balanced and clear and must be provided in a timely manner (Article 48, paragraph 1, Pw).
At the start of participation, pension providers must inform the employee about the characteristics of the pension scheme (Article 21, paragraph 1, Pw). They often use a start letter for this. The characteristics of the pension scheme include stating whether a partner's and orphan's pension on a risk basis is arranged for the participant if the participant dies before retirement and that the survivor's pension stops upon termination of employment (Article 2, paragraphs a and b, BuPw). The pension provider must also inform the participant about the base (the pensionable salary, possibly reduced by a franchise) and the percentage of coverage for the survivor's pension (Article 21 Pw). Pension providers must also provide information about what choices exist with regard to the survivor's pension (Article 2, paragraph d, BuPw), such as voluntary continuation and the choice for commutation at retirement. Finally, it is important that it is clear whether it is a defined or indefinite partner system (Article 2, paragraph a, BuPw) and whether participants still need to take action to register their partner and why this is important (Article 48, paragraph 4, Pw). These elements must be provided in the start information.
Upon termination of participation, pension providers must provide a statement of pension entitlements pursuant to Article 55 Pw (Article 39, paragraph 1, sub a, Pw). This includes, among other things, the amount of the (vested) accrued partner's and orphan's pension. In addition, the amount of the coverage of the partner's and orphan's pension during the continuation coverage must also be provided (Article 6, sub g, BuPw) and attention must be drawn to the expiration of the risk coverage against the risk of death (Article 6, sub h, BuPw) and the possibility to voluntarily continue the risk coverage for survivor's pension (Article 6, paragraph g, BuPw). Regarding voluntary continuation, Article 10bb BuPw prescribes that former participants in the continuation coverage must be provided with information about this right of choice. Pension providers must provide the former participant with information about the registration period, the amount of coverage, the period during which the right to this continuation can exist, that the premiums for voluntary continuation are deducted from the pension capital and that the voluntary continuation can be cancelled monthly.
At the commencement of the old-age pension, the pension provider provides the pensioner with information about their pension (Article 43 Pw). In this information, regarding the survivor's pension, at least the amount of the partner's pension entitlement must be included (Article 43, paragraph 1, sub b, Pw) and for whom the partner's pension is. This also applies to the orphan's pension, if this is part of the scheme after the pension date. If there is no partner's pension after the pension date, this is relevant information for the participant (Article 43, paragraph 1, sub e, Pw), because it is a confirmation of the choice made.
ANALYSIS
REPORT
When the participant or pensioner dies, survivors may be entitled to a pension benefit. They then become pensioners and receive information about their survivor's pension. For the survivor, this is often the first time they themselves come into contact with the pension provider. The pension provider must provide the amount of the survivor's pension (Article 43, paragraph 1, sub a, Pw).
If the pension provider applies a spreading period of more than five years or applies equal adjustments with spreading, the pension provider is obliged to include a specific text about the development of the pension benefit. This information must be provided to pensioners, surviving partners and orphans in the information at pension commencement (Article 7a, paragraph 1, sub e, BuPw). They then start participating in the spreading collective. If equal adjustment with spreading applies to the pension right, the pension provider must provide additional information about this (Article 7a, paragraph 2, BuPw).
Other relevant information that the pension provider must provide to the pension beneficiaries is when he will receive the first benefit and the confirmation of choices made, such as the choice whether or not to apply payroll tax credit (Article 43, paragraph 1, sub e, Pw).
Article 49 Pw determines that information can be provided in various ways, namely electronically, in writing or via a website (a MijnOmgeving). If the information is provided via a website, the participant, former participant, former partner or pension beneficiary must be personally alerted to this information. The AFM considers the information to be provided if, on the basis of the personal alert, it is clear to the recipient what information can be found via the relevant link, why it is important that the participant takes note of this information and a direct reference is included to the place(s) where the information is located. With a direct reference, the participant does not need to search in the portal to find this information. The information provided electronically or via the website must be retained for one year after the death of the pension beneficiary or the expiry of the survivor's benefit. A pension provider must therefore ensure that the information is reproducible.
ANALYSIS
REPORT
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