AFM Guidance 1 min read

Samenwonen of weer uit elkaar? Check regelmatig relatiestatus deelnemer

RegCanary analysis of a AFM publication

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Why it matters

RegCanary's analysis of what this means for regulated firms.

While marital and registered-partnership status flows automatically through the Basisregistratie personen (BRP), the status of unmarried cohabitants does not, leaving pension providers reliant on member-reported data. Where that data is stale or missing, members risk incorrect survivor benefits at death or a miscalculated pension at retirement, and providers face disputed claims, complaints and potential remediation costs. For compliance and operations teams outside the Netherlands, the message is a useful benchmark: relationship-status data quality is a recognised supervisory concern in lifecycle and beneficiary processes, and it sits at the intersection of data integrity, conduct risk and customer outcomes.

Firms with cross-border Dutch exposure — or with pension, protection or wealth operations in the region — should treat this as a prompt to review how dependent status is captured, evidenced, refreshed and reconciled against external registries. What this means for compliance teams: member-facing disclosure must be clear enough that cohabitants understand the need to self-report changes; onboarding and periodic review journeys should prompt for relationship-status confirmation; and records should be retained to demonstrate reasonable steps were taken. Where automatic registry feeds exist for married or registered partners, consider whether equivalent verification can be sourced for cohabitants.

Recommended actions: (1) map where relationship status is captured and by whom; (2) review member communications for clarity and frequency; (3) test a sample of cohabitant records for completeness; (4) document remediation and escalation routes for disputed beneficiary claims; (5) log the issue on the conduct risk register.

Who this affects

Sectors and firm types identified in the analysis.

  • General Regulation

Source

AFM

Original publication, 13 November 2026

Read the original publication (opens in a new tab) afm.nl

This is RegCanary's analysis, not the regulator's text. It summarises and interprets the publication above; it is not the AFM's original wording, and it is not legal advice. Always rely on the original source.

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