Final transition date for the pension system remains January 1, 2028; third progress report by the Government Commissioner
Publication date: July 7, 2025
The Government Commissioner for the transition of the Dutch pension legislation issues a regular advisory report twice a year to the responsible minister. The third report was published on June 19, 2025. It is based on data up to May 30, 2025, and combines quantitative monitoring information from, among others the supervisory bodies DNB and AFM, and the Ministry of Social Affairs and Employment with qualitative insights from discussions with stakeholders in the pension sector. In short: progress is being made, pressure remains high, and postponement is undesirable.
Transition dates are shifting
A clear shift is visible in the planned transition dates of pension funds. For the first time, more funds are planning to transition on January 1, 2027, than on January 1, 2026. An increasing number of funds are scheduling the transition for the second half of 2027 or on January 1, 2028. It is still expected that more than half of the participants will have transitioned by January 1, 2026, implying that especially smaller funds have postponed their transition moment.
Insurers and premium pension institutions (PPIs) still need to convert approximately 50,000 implementation agreements. For insurers, a significant portion of the conversions is concentrated on the final transition date (January 1, 2028), which poses risks regarding implementation capacity and tax compliance. For PPIs, the distribution across the years appears more balanced.
Why is there a delay?
Employers are postponing conversions for various reasons: financial motives, organizational restructuring, sectoral hesitation, and political uncertainty about legislation. This will lead to a peak workload at the end of the transition period. The Government Commissioner warns of the risk that, due to delays, there may be insufficient capacity among pension executors and consultants, potentially resulting in the absence of a valid pension scheme by 2028—with all the associated risks.
General impression and outlook
The transition is progressing steadily. Almost all pension fund transition plans are ready. Collaboration across the chain is strong, despite the high workload. However, some funds are postponing their transition moment due to delays in assessments by supervisory bodies or readiness for implementation. The distribution of transition moments throughout the year (in addition to January 1, also April 1, July 1, and October 1) is encouraged.
The pressure remains high, especially toward January 1, 2026, when large funds will also transition. The experiences of early adopters are being widely shared. For insured schemes, the pace of conversions is still insufficient, but the sector considers 2028 achievable—provided that conversion processes for 2027 begin in the fall of 2025. Within the pension sector itself, there is little support for postponing the final transition date.
Conclusion
Based on current information and discussions, the Government Commissioner sees no reason to reconsider the final transition date of January 1, 2028. The next report will again assess the feasibility of this date.
