The Dutch Pension Federation has urged the government to be very clear when implementing European legislation on sustainability reporting that this does not apply to pension funds.

The call for clarification was made in its response to the consultation on the implementation of the Corporate Sustainability Reporting Directive (CSRD) in Dutch legislation, which emphasised that the CSRD only applies to companies.

The federation explained that pension funds, meanwhile, are foundations and therefore do not have to comply with the rules.

In addition to this, it pointed out that pension funds are already subject to another reporting framework that applies specifically to the financial sector: the Sustainable Finance Disclosure Regulation (SFDR).

However, it acknowledged that there is confusion amongst pension funds and accountants as to whether the CSRD could apply to pension funds that have been designated as public interest entities (PIE).

This is because there are different types of PIE and because the regulations consist of a complex stack of laws and revisions.

Despite the industry confusion, the federation said that it believes that no pension fund, regardless of PIE status or not, falls within the scope of both the CSRD itself and the draft version of the Dutch implementation.

However, to prevent incorrect implementation of the legislation, it called for the government to very explicitly explain which organizations with PIE status are intended by the implementation law.

The federation suggested that this could be done with a supplement in the explanatory memorandum, arguing that this would "avoid a lot of discussion and possibly unnecessary costs".

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