Governance vulnerability
The AFM observes that the content of transition overviews is improving. This is a step forward. At the same time, structural vulnerabilities remain. Differences between the old and new systems are still not sufficiently explained. Compensation often remains implicit, especially for pensioners and deferred beneficiaries. And participants lack guidance to understand the impact on their own financial situation.
These are not details. These are risks of foreseeable disappointments. And that is precisely where the governance vulnerability lies.
Communication is part of decision-making
The pension transition isn’t just about rules and systems. A fundamental shift is taking place from collective promises to individual pension assets that fluctuate with returns and risks. This has direct consequences. Outcomes become personal, and fluctuations become visible. Decisions are assessed retrospectively on their effect, not on intention.
That’s why communication can’t follow decision-making. Communication is part of the decision itself. Policy choices that can’t be explained within a comprehensible asset context won’t hold up administratively.
Information doesn’t stick
Participants increasingly view their pension in conjunction with their overall financial situation. Pension feels increasingly become part of their own assets. If communication gets bogged down in regulatory techniques, legal explanations, or project jargon, distance and misunderstanding arise. The figures are correct, but the meaning is missing.
Information reaches participants, but doesn’t stick. This demonstrates that administrative responsibility begins with interpretation. Without an asset context, participants don’t understand what risk, return, and redistribution mean for them. And without effective, empathetic client journeys, they don’t either.
Core process
The AFM is clear: communication must be structurally established as a core process. It must be embedded in governance, decision-making, and evaluation. This also applies after the transition. This requires early involvement of communication officers in policy choices. It requires explicit attention to participant understanding in decision-making. It requires assessing whether communication leads to realistic expectations. And it requires continuous monitoring (and improvement where necessary), even after the transition.
In practice, we still too often see communication as the last step. In a system where risks lie more directly with participants, this is unsustainable.
Conduct supervision
The AFM explicitly warns against information that leads to foreseeable disappointments. This undermines public support for the new system. For fund governance, this translates into reputational risk, loss of trust, and increased pressure from accountability and complaints. Fluctuating outcomes are part of the system. Unexplained outcomes are not. Therefore, expectation management is not just a communication issue but also part of risk management.
The AFM’s vision extends beyond the transition years. Starting in 2029, behavioral supervision will play a greater role. In a system with individual assets, the provision of information, choice guidance, and financial transparency will become structurally more important. The pension transition, therefore, has no end point. The board’s responsibility for clear and balanced communication remains, as does the obligation to continuously improve and adapt it to the social and technological context.
A solid foundation
The pension transition highlights what has been going on for some time: board decisions are assessed based on individual pension assets. This requires communication that not only explains what has been decided but also helps understand its implications. Making participant communication a core process not only strengthens trust but also enhances board resilience.
Structurally embedding participant communication in governance, behavior, and asset insight requires an integrated approach that combines technology and content, precisely what our PensionSuite is designed for.
