Daan Kleinloog: ‘Er is te weinig marktwerking onder PUO’s’

For compliance and conduct teams, this is not a new rule or supervisory measure, but it signals areas likely to attract scrutiny as the pension transition progresses. Firms should assess how provider selection, pricing and service quality are evidenced in competitive terms, and whether reserve design or transfer arrangements could create frictions for members changing jobs. Pension providers, insurers and asset managers should review governance around solidarity reserves, member communications and portability, and ensure that product design decisions are defensible from both a prudential and conduct perspective.

Action points: map PUO dependencies and competitive benchmarks; test whether solidarity reserve mechanics affect member mobility or exit/entry treatment; review participant disclosure for clarity; and monitor AFM commentary for evolving expectations. No immediate filing or rule-change obligation is indicated, so implementation complexity is low, but early gap analysis can reduce future supervisory and reputational risk.