Risk & Compliance Pensions

Feedback AFM on pension transition communication plan

Date:September 27, 2023

To manage the pension transition in the Netherlands, pension providers are obliged to draw up a transition communication plan. From 1 July 2023, these plans can be submitted to the Netherlands Authority for the Financial Markets (AFM). Due to the staggered submission of the plans, the regulator has already had the opportunity to assess some of the plans. In this article, we list the most important feedback from the AFM.

Guidance on the Communication Plan 

The AFM published preliminary guidance on the Communication Plan earlier this year. This was updated and finally published on 30 June. This guidance describes quite extensively what the Communication Plan should meet:

  • Description of and communication per target group 
  • Concrete and realistic goals 
  • Communication moments and messages 
  • Substantiating choices (why) 
  • Evaluation and adjustment of communication 
  • Substantiating correct participant communication 

Tips & tricks 

On 12 September, the AFM published its interim feedback on the first plans. The main line of these learning points:

  • Record in the communication plan which message, by which means of communication, to whom and when, is communicated and what the goals are.
  • The communication plan should clearly show what the pension provider will do and which choices have been made. For instance, choices regarding target group segmentation or planning choices.
  • In the communication plan, visibly take into account the context in which the communication should take place. It is wise to take signals or current developments, such as specific concerns of participants, into account in the communication plan.
  • Objectives should focus on the effect you want to achieve among participants. A measurement among advisers or participants is not a goal, but it can be a means of determining whether the goal has been achieved. A goal could be that x% of active participants know by a certain date that the pension system is changing and what the concrete consequences are for them. 
  • Make clear what goal, what message is being measured at what time.


The AFM’s guidance and interim feedback align well with previous publications on communication with customers in the financial sector. Although the requirement to draw up a communication plan is new, the AFM’s expectations are fairly similar to those in other situations such as investment insurance and redemption-free mortgages. We have extensive experience in these and similar processes, so if you need support, please feel free to contact us.

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