WealthTech company Kidbrooke has outlined why the Netherlands’ transition to the Wet toekomst pensioenen (Wtp) has redrawn the lines of accountability in pension communication.
In an analysis published by Kidbrooke, the firm illustrates the problem through a scenario playing out across the Dutch market. A pension adviser meets an SME employer to discuss the Wtp transition. They cover contract duration, costs and compensation. Participants are not mentioned. Three months later, a warehouse worker receives a transition overview showing two numbers: what he had, and what he will get. The explanation is identical to the one received by the 24-year-old intern and the 58-year-old warehouse manager. Under Dutch regulation, accountability for that explanation rests not with the adviser or the employer, but with the insurer.
Built for trust, not explanation
Kidbrooke argues this was not always a problem. Under the old defined benefit system, the pension promise was fixed — a set percentage of salary at retirement. Participants needed to work, not to understand investment risk. Annual statements confirmed accruals; trust substituted for comprehension. The adviser mediated between insurer and employer, and the model held because the product was straightforward: premium in, pension out.
That logic no longer applies, Kidbrooke said. In a defined contribution scheme, the outcome depends on investment returns, interest rates, lifecycle allocation and participant decision-making. As Kidbrooke puts it, pension is no longer a promise participants passively receive — it is an outcome partly determined by what they understand and decide. The accountability implications are significant.
What the AFM has already found
The AFM has been unambiguous: information must be correct, balanced, clear and timely, and that obligation rests with the insurer regardless of how the distribution chain is structured. Kidbrooke draws on a series of regulatory findings to show how far the sector currently falls short.
In its Platform Pensioentransitie report from March 2025, the AFM found that transition overview explanations are overwhelmingly generic, with all participants receiving identical text regardless of age or lifecycle stage.
Reporting on the AFM’s Lessons Learned publication from September 2025 revealed calculation errors across multiple insurers and PPIs. The regulator has also repeatedly flagged the risk of unrealistic expectations where optimistic projections are shown without adequate contextualisation of downside risk.
In January 2025, the AFM wrote to the Minister of Social Affairs stating it had “serious concerns” about the timeliness and quality of insurer transition communication.
The infrastructure gap
Kidbrooke identifies the root cause as operational rather than intentional.
The firm positions its forecasting, planning and scenario simulation APIs as a direct solution, enabling insurers to embed participant-level personalisation into existing communication workflows without overhauling core systems.
For more insights, read the full story here.
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