Dutch pension funds and administrators have been urged to be more discerning about the completeness and substantiation of their transition plans and documents, ahead of the 1 January 2025.

Early adopters are facing growing pressure to be the first to transition to the new system, with De Nederlandsche Bank (DNB), which is responsible for the review process of transition notifications, expecting some 70 notifications by March 2025.

Speaking at the APG Summer conference, De Boer said that the transition notifications and requests for partial assessments are already trickling in at DNB.

“There are currently ten completed transition notifications. We expect that number to rise to seventy by March of next year,” he said.

Whilst De Boer acknowledged that this is a big “task” in which a “controlled and balanced transition” is central, he argued that “we are ready for it; we can handle this. We have nine assessment teams ready".

De Boer also emphasised that the regulator is expecting a "rapidly rising learning curve”, pointing out that administrators and funds have been given further clarity on the regulatory expectations facing them, with DNB already in discussions with funds that have submitted a dossier.

“From those conversations it became clear that for administrators and pension funds the transition template and the corresponding instructions for completion were not yet sufficiently clear,” he said.

“For example, funds indicated that it was not clear that all documents to which a fund refers in the transition template or in underlying documents must also be sent with the dossier. In addition, they felt that a number of completion instructions needed to be written up more comprehensibly. So, we worked on that.

“An improved transition template has been available since the end of August. Please use it, as DNB expects pension funds that submit a transition notification or partial assessment to use the most up-to-date version of the transition template.”

De Boer also highlighted the broader support available for Dutch pension funds and administrators, emphasising that DNB is supporting administrative organizations and funds with their transition notification in numerous ways.

“We inform, guide and structure...The new transition template is an example of how we are structuring the process better," he said. "And the guidance is done through expert sessions and the oral explanations of the letters.

However, De Boer admitted that whilst detailed explanations can be done at this point, the regulator will not be able to continue this when the number of transition notifications goes up, warning that "there will have to be a learning curve".

Given this, De Boer urged administrators and funds to share the available documentation with everyone involved with the transition template.

“Secure what is already available, such as up-to-date knowledge documents and Q&As, and share them with the organization," he said.

"That will benefit the process. In addition, set the bar high, be critical and don’t say yes too quickly.

"For example, ask yourself whether someone who has not sat at the board table for the past three years will be able to comprehend and reproduce the information, based on the information submitted, the steps taken, the considerations made and the conclusions drawn.”

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