*Please note: this article is tailored to the Dutch market.
The AFM has published its priorities and key activities for the pension sector in 2025. While no new tasks have been added for this sector, the AFM is further expanding its supervision this year. This intensification highlights the importance the AFM places on overseeing the pension sector.
A key priority for the AFM is ensuring that new pension schemes align with participants’ needs and prevent disappointment. The following investigations have been announced:
In addition to these investigations, this year’s focus will be on assessing the many communication plans related to the pension transition. The regulator will also once again publish its annual ‘Sector in beeld: pensioenen’ report, based on a sector-wide survey.
What stands out about these priorities is that they are all follow-up investigations. This suggests that the AFM still sees sufficient reason to closely monitor these issues given their importance. The regulator also explicitly refers to its guidance documents, reinforcing the need to properly integrate this supplementary guidance when applying regulatory standards.
It is expected that stricter measures will be taken in response to key findings. The sector has already received insight into the AFM’s interpretation of regulatory standards through its guidance and reports. Last year, the AFM issued several publications clarifying its expectations on choice guidance and communication, partly based on findings from assessments and investigations.
Now that the regulations have been in effect for some time and exploratory research has provided better insights, the new investigations will take on a more formal character. As a result, enforcement measures may be applied more swiftly as a supervisory tool.
In this first year of transition, the AFM has set clear priorities and made strategic choices. Similar to fellow regulator DNB, which has also defined key focus areas, the AFM is concentrating on the transition process, with particular emphasis on communication standards and duty of care, all viewed from the perspective of participant interests.
The supervisory authorities’ focused approach can help the pension sector prioritise its efforts during these transition years. It is clear that the AFM considers communication, choice guidance, risk preference research, and engagement confirmation to be core themes for the sector. It would be prudent to integrate all available guidance on risk preference research and engagement confirmation when preparing for these processes.
For ongoing obligations, we recommend that the pension sector critically review its choice guidance policy and communication with participants. The legislator and the AFM place significant responsibility on the pension sector. Choice guidance goes far beyond merely informing participants about their options or providing a tool—it must be designed with participants' best interests in mind. If the AFM identifies shortcomings this year, recommendations and guidance alone may no longer suffice.
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