Negatief AFM-advies over voorgestelde UPO-modellen voor 2027

The regulator’s core concern is that the proposed templates do not meet statutory cost-transparency requirements and therefore fall short of the participant-interest standard. For compliance teams at pension providers and insurers, this is a clear signal that cost-disclosure design remains under supervisory scrutiny and that adopting industry templates without independent legal validation carries regulatory risk. Firms should treat the current proposals as unresolved, not as an approved implementation path.

Priority actions include reviewing the cost-information sections of proposed UPO templates against applicable transparency rules, documenting the rationale for any template choices, and engaging early with industry bodies and SZW on revised models. Providers should also assess data and systems readiness for any redesign and prepare participant communications that remain accurate if templates change. The negative advice may create short-term uncertainty and rework, but it also creates an opportunity for firms with robust cost-data governance to demonstrate compliance maturity and build trust through clearer participant disclosures.

RegCanary recommends close monitoring of the minister’s response and any revised UPO models ahead of the 2027 reporting cycle.