Data quality should be viewed as an “ongoing governance challenge” rather than a one-off migration exercise after transitioning to the new pension system under the Dutch Future Pensions Act (Wtp), according to pension administrator AZL.

In a blog post, AZL team lead, data and risk, Frank Cremers, argued that data quality has become an “explicit precondition” for a responsible transition to the new pension system, adding that it is shifting from an operational issue to a governance issue.

Cremers noted that under the Wtp, existing pension rights are translated into individual pension capital.

“This means the quality of the underlying data has a direct impact on members' pensions,” he said, warning that an error that could have been easily rectified under the old system could be more difficult to correct after the transition.

For this reason, De Nederlandsche Bank (DNB) requires pension funds to demonstrate that the data underpinning their decisions is complete, accurate and reliable.

Cremers said this calls for repeatable controls, documented analyses and an audit trail that demonstrates how checks and analyses were carried out.

Therefore, governance takes a more prominent role under the new system.

“Who owns the data? What controls are in place? How is data quality monitored? How are incident management and escalation procedures organised? The aim is to ensure that data remains reliable throughout the migration process and beyond.

“As a result, data quality is no longer a one-off exercise but an ongoing governance challenge – not only before the transition, but throughout the entire lifecycle of pension administration,” he said.

He identified collaboration between pension fund boards, administrators, migration teams, data analysts and compliance specialists as a key to an effective approach.

Furthermore, Cremers said the “biggest misconception” about data quality is that it is a project with an end date, when in reality, it becomes a “continuous process” under the Wtp.

“Pension funds that want to remain sustainably in control need to invest in a mature data governance framework, clear data ownership and a robust Plan-Do-Check-Act (PDCA) cycle.

“Continuous monitoring, validation, issue management and data lineage – the ability to trace the complete journey of data through systems and processes – become essential components of day-to-day operations,” he explained.

He added that pension administrators have an important responsibility to support pension funds in achieving clean data before the transition, while also helping them to establish the governance, management information and control measures needed to safeguard data quality permanently.

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