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Pensioenfederatie (Federation of the Dutch Pension Funds)

PF

The Federation of the Dutch Pension Funds represents the interests of occupational pension providers to ensure high-quality retirement systems.

Lobbying Activity

Response to Strategy on Intergenerational Fairness

11 Nov 2025

How occupational pensions contribute to intergenerational fairness The Dutch Federation of Pension Funds supports the Commissions Strategy on Intergenerational Fairness. Pensions are key to balancing financial responsibilities, risks and benefits between generations. Ageing makes pay-as-you-go systems unsustainable, placing a heavy burden on younger people and reducing benefits for retirees. Funded pensions offer greater resilience, so we urge the Commission to promote capital-funded pensions. Adress the creeping ageing crisis The creeping ageing crisis is a megatrend and demographic challenge for Europe. While longevity is a blessing, the projected increase in age-related public expenditures, particularly on pensions, healthcare, long-term care, and education, poses a substantial fiscal challenge for future generations across the European Union. Member States should be encouraged to take appropriate reforms and measures. To make sure that every citizen has pension rights and lives old age in dignity, the European Commission should promote the development of occupational pension systems, for example by fostering automatic enrolment in occupational pension schemes. Promote pension transparency To give citizens a better understanding of their pensions and plan their future, pension tracking services should be introduced in Member States that currently do not have them. Pensioners that have an adequate pension income consume also more, which is good for local economies. To help mobile workers who have pensions in multiple countries, the European Tracking Service (ETS) on Pensions needs to be acknowledged, so mobile workers stay up to date concerning their pensions and are activated to get their pension in order. Include pension adequacy in economic governance Funded pensions play a vital role in attaining pension adequacy. They also improve national fiscal sustainability, as they are funded by participants themselves rather than paid by shifting an increasing burden on younger generations. Shortcomings in either pension adequacy or fiscal sustainability influence European economic stability and growth. For this reason, pension adequacy must be incorporated in the European Economic Governance Framework. Member States should set measurable goals with clear policies and milestones to tackle pension and ageing challenges. Country-specific recommendations should emphasize pension adequacy alongside financial sustainability. Additionally, access to EU funding should be conditional on progress in pension reforms. To support Member States in strengthening their occupational pension systems a European working group on ageing should be formed to formulate a Pension Policy for a Social and Competitive Europe. In general, DG EMPL, DG TAXUD, DG ECFIN and DG FISMA should coordinate social, economic and employment aspects and make ageing and occupational pensions more prominent in the European Union. Close gender pension gaps There are major gender pension gaps. Pension systems mirror labor market realities. Lower pay, shorter careers, career breaks and part-time work lead to lower pension contributions. Women often bear the brunt of unpaid care due to cultural norms, impacting their pensions. We should not let those who care for our children and elders forego on their pension. As ageing increases demand for informal care, it is in societys interest to support pension rights for caregivers. Member States should find ways to recognize care work within their pension systems. Gender pension gaps widen at each life event. The European Commission should facilitate the exchange of best practices around closing gender pay and pension gaps around life events. For example, equal division of state and occupational pension rights should be the default option in case of divorce or separation. And survivor benefits for widows and widowers could be promoted in occupational pension schemes.
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Meeting with Vincent Hurkens (Cabinet of Executive Vice-President Stéphane Séjourné)

7 Oct 2025 · IORP, SFDR

Meeting with Dirk Gotink (Member of the European Parliament)

11 Sept 2025 · Pension funds

Meeting with Maria Luís Albuquerque (Commissioner) and

30 Jun 2025 · Information exchange.

Dutch pension funds urge accessible sustainability categories in SFDR

30 May 2025
Topic — The European Commission is reviewing rules for sustainability disclosures in financial services.
Message — They want sustainability categories made accessible for institutional investors with diversified portfolios. They advocate for using non-regulatory channels like websites to inform participants. They also suggest excluding government bonds and derivatives from threshold calculations.123
Why — These changes allow pension funds to maintain sustainability labels while holding mandatory low-risk assets.4
Impact — Transparency advocates lose a complete and comparable overview of a fund’s total investment impact.5
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Meeting with Lara Wolters (Member of the European Parliament)

20 Mar 2025 · SIU and sustainable finance

Response to Savings and Investments Union

7 Mar 2025

Please find the feedback of the Dutch Federation of Pension Funds attached.
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Meeting with Lara Wolters (Member of the European Parliament)

4 Sept 2024 · Economic policy

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and APG Groep NV

11 Jun 2024 · Recommendations of the Dutch pension sector for the new mandate

Meeting with Nicolo Brignoli (Cabinet of Executive Vice-President Valdis Dombrovskis)

11 Jun 2024 · shared ideas on the future of the Capital Market Union and focused on the challenges in keeping pensions in Europe financially sustainable.

Meeting with René Repasi (Member of the European Parliament)

20 Feb 2024 · Exchange of Views

Meeting with Ondřej Kovařík (Member of the European Parliament, Shadow rapporteur)

24 Jan 2024 · FIDA

Meeting with Frances Fitzgerald (Member of the European Parliament, Shadow rapporteur) and The European Digital Payments Industry Alliance

22 Jan 2024 · FIDA

Meeting with Caroline Nagtegaal (Member of the European Parliament)

17 Jan 2024 · FIDA

Meeting with Paul Tang (Member of the European Parliament, Committee chair)

17 Jan 2024 · FIDA

Meeting with Eero Heinäluoma (Member of the European Parliament, Shadow rapporteur)

1 Dec 2023 · Framework for Financial Data Access and amending Regulations (EU) No 1093/2010, (EU) No 1094/2010, (EU) No 1095/2010 and (EU) 2022/2554.

Dutch Pension Funds Urge EU to Cut Reporting Burdens

28 Nov 2023
Topic — The European Commission initiative aims to reduce company reporting requirements by 25 percent.
Message — The federation requests reducing derivative trading reporting from daily to monthly and extending trade repository deadlines. They also seek to eliminate duplicate reporting requirements between SFDR and other sustainability frameworks.123
Why — Lowering compliance costs would help preserve the value of pension benefits for members.45
Impact — Financial regulators would lose immediate access to granular data used to monitor market transparency.6
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Dutch pension funds seek tailored rules for data sharing

11 Oct 2023
Topic — The European Commission is consulting on a framework for sharing financial data across sectors.
Message — The Federation requests four-monthly updates and the exclusion of disability pension data to prevent exclusion. They also argue that insurance-based pension products should be included in the regulation.12345
Why — Tailored standards would help avoid costly administrative overhauls and reduce unnecessary data management expenses.67
Impact — Commercial data users lose the ability to influence technical standards and functional data sharing designs.8
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Dutch pension funds urge inclusion of transparent investment funds in FASTER

15 Sept 2023
Topic — The European Commission's proposal for a common EU-wide withholding tax relief system.
Message — The organization calls for including transparent investment funds to prevent significant investment losses. They also request limiting Member State exemptions so pension funds benefit from faster refunds.12
Why — Faster tax relief allows pension funds to reinvest capital quickly, generating millions in returns.3
Impact — National tax authorities lose the power to exclude institutional investors from streamlined procedures.4
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Dutch pension funds urge mandatory sustainability reporting standards

7 Jul 2023
Topic — New EU standards defining how companies must disclose their environmental and social impacts.
Message — The federation wants sustainability reporting made mandatory rather than voluntary to ensure data consistency. They argue that allowing companies to self-evaluate their climate impact creates problematic data gaps for investors.123
Why — Reliable corporate data would allow pension funds to fulfill their own legal reporting requirements.4
Impact — Financial firms face a heavier regulatory burden if companies do not provide standardized data.5
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Response to Enhancing the convergence of insolvency laws

17 Mar 2023

The Dutch Federation of Pension Funds highly values the European Commissions proposal for a Directive harmonizing aspects of insolvency law. It is a vital building block towards the completion of the Capital Markets Union. In line with a recent appeal by European leaders, we call upon EU institutions to set a fast pace for the CMU agenda. We urge them to build on the work of the Next CMU High-Level Expert Group. We are convinced that Europes pension funds play a vital role. Pension funds invest money in diversified long-term portfolios with a long time horizon. They are important shareholders of quoted companies and provide debt funding for corporate capital investments. Notably, in countries with (quasi)-mandatory occupational pension systems households hold most assets in capital markets, thereby deepening cross-border capital markets. Modernizing Member States insolvency regimes increase faith in investors ability to retrieve residual value of cross-border investments in firms that fail. Insolvency procedures are currently lengthy and the diversity of regimes means that investors can be hesitant to commit to higher risk foreign investments, as they struggle to assess the implications of insolvency. We therefore welcome the way in which the Commissions proposal makes insolvency proceedings more efficient. We do see shortcomings with regards to the position of employees in pre-pack proceedings. The proposals mean a deterioration of their rights compared with current Dutch legislation. We would specifically like to point at the treatment of unpaid pension premiums in pre-pack proceedings, in which employees are effectively creditors. Pension premiums are part of the obligations under the employment contract. Pension premium liabilities should therefore be transferred in a pre-pack sale. Amendments are needed to guarantee pension premium payments in coherence with the IORP II Directive [(EU) 2016/2341] and the Directive on restructuring and insolvency [(EU) 2019/1023]. Please see the attached letter for more detail on our proposed amendments.
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Meeting with Lara Wolters (Member of the European Parliament, Rapporteur)

8 Feb 2023 · Staff level: CSDD Directive

Meeting with Lara Wolters (Member of the European Parliament, Rapporteur)

26 Oct 2022 · Due diligence

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

7 Jul 2022 · Webinar on RePowerEU

Meeting with Esther De Lange (Member of the European Parliament)

1 Jun 2022 · Introductory meeting - APA

Dutch pension funds urge CSDDD alignment with international standards

23 May 2022
Topic — The consultation concerns new EU rules on corporate sustainability due diligence obligations.
Message — The Federation requests alignment with OECD guidelines to clarify investor obligations. They seek specific definitions for secondary market trading and minority shareholding.12
Why — Clear rules would help pension funds reach their responsible investment goals.34
Impact — Victims of corporate abuse might lose access to remediation from investors.5
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Meeting with Nicolas Schmit (Commissioner) and

9 Dec 2020 · Meeting on pensions, ageing and the action plan on Capital Markets Union (CMU).

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

24 Nov 2020 · Online conference on the European Green Deal and Climate policy

Response to Review of the VAT rules for financial and insurance services

19 Nov 2020

Dutch pension funds are strongly committed to deliver pension services on behalf of and in the interest of those who work in the Netherlands, either living in the Netherlands or any other Member State. They seek for the lowest cost and the appropriate investment policy (maximizing risk-adjusted returns) and structure their activities according to these objectives (either through insourcing or outsourcing). We highly value the possibility to express our opinion with regard to your roadmap and kindly bring two issues to your attention. We feel these issues are helpful in assessing the special position of pension funds in the European Union (EU). In particular, we strongly believe that VAT burden on pensions should be avoided, both during the accrual and decumulation phase The recent report of the High Level Group of pension experts (HLG) states that, although joint efforts to enhance adequate pension savings within the European Union (EU) exist, more effective policies are needed. Whilst addressing the issues identified (lack of VAT neutrality and legal uncertainty), we suggest the following should be taken into account:  the very specific position of pension funds and/or services to pension schemes; and,  the importance of pension funds and/or vehicles that manage pension schemes as low cost carriers. The HLG stresses the importance of pension funds as low cost carriers and refers to the OECD Pensions Outlook 2018 which calculates that annual costs and charges of 1% of assets will reduce final pensions with 21.3% in DC plans. Although Member States apply different combinations of taxation and exemption, the majority of Member States apply for EET. Similarly, principle 15 of the European Pillar of Social Rights stresses the importance of taking into account the right of EU workers to a pension commensurate to their contribution and ensuring adequate retirement income. We suggest an approach by the EC in which taxation of pensions, whether services-based or margin-based, is prevented or at least postponed to the moment of pay-out. We also believe that both neutrality and simplicity with regard to VAT is achievable for pension funds and/or any pension scheme in the EU We feel the European Commission’s efforts to enhance pension savings and pension adequacy makes it possible to suggest neither the services of pension funds and/or vehicles that manage pension schemes nor the (management) services they receive are being levied with VAT, irrespective of a services-based or margin-based approach. Pension funds and (management) services provided to pension funds or any pension scheme can be well defined so unclear case law and complexity are prevented, while creating a level playing field across the EU. Addressing the issue in the definitions will prevent complexity and enhance neutrality. This seems highly desirable since the present VAT Directive lacks a proper definition with regard to pensions and leads to (negative) consequences in some Member States that were not foreseen in the 1970s. We look forward to the upcoming consultation, which we intend to use to further communicate our position. In case you have any questions, please contact Mr. Matthies Verstegen (verstegen@pensioenfederatie.nl) at our Brussels office or Mr. Gerard Metske (metske@pensioenfederatie.nl) at our The Hague office. We would be available to further discuss the matter at your request.
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Meeting with Vasiliki Kokkori (Cabinet of Commissioner Marianne Thyssen)

23 May 2019 · Future of pension adequacy linking it to the European climate agenda

Response to Review of the European Supervisory Authorities

19 Jan 2018

It is important to note that IORPs have two perspectives when it comes to supervision: IORPs are social institutions IORPs are subject to national social and labour law and thus national supervision. As social institutions IORPs are organised very differently from Member State to Member State. In this context, from a European perspective, EIOPA is the relevant authority. IORPs are active on financial markets Pension funds are active on financial markets to provide a good retirement income for beneficiaries. In that respect, well-functioning capital markets across the EU are important. We therefore welcome supervisory convergence and the consistent application of the EU Single Rule Book. In this context ESMA is the relevant authority. We agree with the position of the Dutch government that with regard to changes of the governance of the ESAs, form should follow function. Thus, according to us, changes in the governance structure are only needed, if an ESA gets more competences (which is only the case for ESMA). NCAs should be independent when deciding on supervisory policy for national IORPs based on national labour law and social conventions. The status quo of the powers and mandates of EIOPA concerning IORPs should be kept as described in the IORP II directive. With regard to capital markets, ESAs can and should play a far greater role. Nonetheless, we feel that also in this respect, the added value of NCAs needs to be preserved. A right balance between maintaining the NCAs’ current roles on the one hand and enhancing ESMA’s role in mainly creating more supervisory convergence on the other hand needs to be struck. For capital markets, combining both national and European factors would be better than replacing one by the other. We call for a sound, solid and transparent governance structure of both EIOPA and ESMA. As for EIOPA, NCAs should keep a major role. Board members of ESAs need to have an in-depth knowledge of occupational pensions. We call for an active role of the EP and the EC in order to safeguard sufficient democratic legitimacy and accountability of European supervision. We are against industry funding of the ESAs as it should be commensurate to the respective supervisory tasks at European level. As IORPs are supervised at national level we see no need for additional financing of EIOPA by the pension sector. More in general, we do not think there will be a payment mechanism that could objectively be justified in terms of the right sector participants paying the right amount of (indirect) supervision costs. Large sectors such as the Dutch pension sector, will most likely end up paying a disproportionate amount - costs that ultimately will have to be borne by beneficiaries. Comparing stress test results between individual IORPs from different Member States has little added value, since the results should be interpreted within the national supervisory framework differing greatly from country to country. Reducing and streamlining reporting requirements should be high on the priority list. Simplification should be achieved where possible and an overarching assessment of reporting burden should be made. Data, including those for statistical purposes, should only be collected by NCAs. We welcome that the ESA Review Package aligns with the Better Regulation Agenda. Implementing and carrying out cost-benefit-analyses should always be the driving force. A continuous dialogue between supervisors and supervised entities should be at the core of efficient and effective supervision. In order to make proper use of the (technical) expertise of market participants, we encourage the ESAs to engage in a continuous dialogue with market participants about the impact of their regulatory work. This can be done through a wider Stakeholder Group participation or on a bilateral basis. There should be no bank bias within the ESRB,neither in its approach to other financial sectors nor through its governance structure.
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Meeting with Jyrki Katainen (Vice-President)

15 Nov 2016 · Dutch pensions and EFSI

Meeting with Mette Toftdal Grolleman (Cabinet of Commissioner Jonathan Hill)

31 Mar 2016 · IOPS; CMU; Challenges for Pension Funds;

Meeting with Valérie Herzberg (Cabinet of Vice-President Jyrki Katainen)

6 Oct 2015 · Capital markets union

Meeting with Ruth Paserman (Cabinet of Commissioner Marianne Thyssen), Vasiliki Kokkori (Cabinet of Commissioner Marianne Thyssen)

6 Oct 2015 · Role of occupational pensions in addressing the adequacy gap in future pensions

Meeting with Marianne Thyssen (Commissioner) and

10 Sept 2015 · Commission’s agenda on pensions and the role of supplementary pensions in ensuring pension adequacy

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis)

25 Aug 2015 · Occupational pensions

Meeting with Vasiliki Kokkori (Cabinet of Commissioner Marianne Thyssen)

14 Jul 2015 · Commission's social policy agenda.

Meeting with Jonathan Hill (Commissioner)

3 Jun 2015 · Capital Markets Union + Financial Services Policy

Meeting with Mette Toftdal Grolleman (Cabinet of Commissioner Jonathan Hill)

24 Feb 2015 · IORPs, own initiative report from EIOPA, CMU from a pension fund view

Meeting with Michel Servoz (Director-General Employment, Social Affairs and Inclusion)

24 Feb 2015 · Réforme des retraites aux Pays-Bas

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis)

14 Jan 2015 · Occupational pensions