Key insights from the AFM on the compliance function at pension funds

On 17 March 2026, the AFM published its supervisory report ‘Compliance at pension funds: in the interest of the participant’. In this report, the AFM highlights the significant added value of an independent compliance function within pension funds. Acting as a critical and independent counterbalance, the compliance function can strengthen the decision-making of a pension fund’s board. Although there is no legal requirement to establish such a function, the AFM sees clear benefits based on a recent exploratory review.

The report follows an assessment of how pension funds organise their compliance function. The AFM engaged with several funds to discuss its structure, positioning and ways of working. While not mandatory, the AFM concludes that having a compliance function offers considerable advantages. A proactive and engaged compliance function can contribute to improved decision-making.

At first glance, the report appears to summarise the AFM’s findings from these discussions. However, several observations stand out and can help optimise the value of a compliance function:

1. A clear role definition and well-defined processes help ensure that participants’ interests are adequately considered in decision-making.
2. Early involvement of compliance in decision-making adds more value than retrospective review alone.
3. An independent positioning of compliance enables earlier identification and mitigation of risks.
4. A broader scope for the compliance function (beyond merely overseeing codes of conduct) enhances the quality and substantiation of decisions.
5. Involvement in communication and guidance supports balanced communication from the participant’s perspective.
6. Visible and accessible compliance officers contribute to a culture in which integrity and compliance are embedded in daily practice.

These observations confirm that the compliance function is most effective when it not only performs a monitoring role, but also acts in an advisory capacity, with sufficient mandate to provide direction where needed.

In 2024, DNB published its Good Practice for the Compliance Function at Pension Funds. We have previously shared the key insights from this publication with you.

Both publications make it clear that supervisory authorities place significant value on a strong and independent compliance function—not because it is mandatory, but because of the value it delivers. Communication with participants and guidance in decision-making are becoming increasingly important under the new pension system. The compliance officer can play a key role in this area and support the board effectively.

Support from Projective Group

Are you looking for a pragmatic and efficient way to establish a compliance function? Projective Group can support you. You may choose to fully outsource your compliance function to us. In doing so, we provide a dedicated expert who can act as an external compliance officer within your organisation. An external compliance officer is particularly well positioned to ensure independence. Clear agreements can be made with the board regarding mandate and responsibilities. Outsourcing offers several key advantages: independence, expertise and continuity are better safeguarded.

If full outsourcing is not what you are looking for, our experts can also support your internal compliance officer and assist with questions regarding the design and implementation of the compliance function.

Would you like to learn more about Projective Group’s vision on compliance in pension funds and how we can support you? Please get in touch.