Our Take
This is a straightforward tooling gap with a clear owner, not a complex coordination problem requiring new regulation.
Why it matters
The AFM designated 2026 as the decisive year for pension transitions while adviser capacity has fallen and conversion processes take 2-6 quarters on average.
Do this week
Dutch pension advisers: audit your insurer data access capabilities this month so you can handle transitieoverzicht communications before Q3 deadlines.
Insurers hold data advisers cannot access
WealthTech firm Kidbrooke identified a structural gap in the Netherlands' WTP pension transition: insurers possess the participant data advisers need for client communications, but no working connection exists between the two systems in practice (per company analysis).
The breakdown occurs during annual reviews. An adviser handles scheme design and compensation for an 80-employee client with a signed transitieplan and approaching transition date. When the employer asks what to tell employees about their transitieoverzicht, the adviser has no answer. Their workflow cannot connect insurer participant data to client-facing scenario analysis.
The AFM concluded in 2024 that informing employees about transition choices is a shared obligation between adviser and pension provider. Joint guidance from Adfiz and the Verbond van Verzekeraars positions advisers as responsible for ensuring transitieplan communications achieve genuine participant understanding, not merely legal compliance.
Capacity constraints make manual fixes impractical
The Government Commissioner's fourth report from January 2026 noted advisers carry an aanjagende rol to push employers toward timely conversion, but acknowledged universal fulfillment is not happening (per government report). The number of qualified pension advisers has fallen while conversion processes average 2-6 quarters.
The AFM wrote to more than 900 pension offices designating 2026 as the decisive year while receiving signals that not all advisers had begun work. Manual workarounds cannot scale under these constraints.
Only insurers can bridge the gap because they uniquely hold participant data, the full product, and regulatory communication obligations simultaneously. This distinguishes them structurally from PPIs, which cannot carry insurance risk or offer guaranteed outcomes directly.
Integration beats bolt-on solutions
Kidbrooke's position is that participant communication capability must integrate into existing adviser workflows rather than function as separate manual processes. Their KidbrookeOne platform offers forecasting and scenario simulation APIs that surface participant-specific was/wordt projections during adviser-employer meetings and participant keuzebegeleiding sessions.
The solution draws on insurers' existing participant data rather than requiring new data collection or manual data transfers between systems.