On 13 January 2026, the Government Commissioner for the pension transition published her fourth progress report. The conclusion is starker than before: the transition of insured pension arrangements is approaching the critical path. The ultimate transition deadline of 1 January 2028 remains in place — but for employers with a pension arrangement held with an insurer or premium pension institution (PPI), delay is no longer an option.
The conversion pace for insured arrangements remains worryingly slow. The main causes are a lack of awareness among (particularly smaller) employers about the scope of the conversion process, the absence of a pension adviser, and contracts without a natural end date. A crucial fact: a conversion takes on average two to six quarters, making the effective deadline for signing offers 1 October 2027 at the latest. Employers who act too late risk having no valid pension arrangement in place by 2028 — with significant tax consequences. Moreover, even employers who opt for grandfathering must still make arrangements for survivor’s pension. Action is therefore always required.
The Minister of Social Affairs and Employment has launched a coordinated approach together with VNO-NCW, MKB-Nederland, FNV, the Dutch Association of Insurers and Adfiz. The Government Commissioner is clear: 2026 is a critical year and this approach must produce tangible results within the near term. Insurers and PPIs have their products ready; advisers have successfully completed the process many times before. Employers have no reason whatsoever to postpone the conversation about their new pension arrangement. Converting the pension arrangement itself requires a pension adviser. However, the conversion process also has an employment law dimension: even where the trigger is a change in legislation, the conversion constitutes an amendment to an employment condition. This involves informing and consulting the works council and guiding the accompanying co-determination process. We are happy to assist you with that