The 2026 Pension Compliance Calendar for European SMEs

How to use this calendar

This calendar maps the recurring pension compliance obligations for European SMEs with employees in the UK, Germany, Netherlands, and Sweden/Nordic region. It is structured as a month-by-month reference rather than a comprehensive regulatory guide — the assumption is that HR teams reading this understand the basics of each regime and need a practical prompt for what happens when.

The obligations listed are the recurring annual obligations. One-off obligations (scheme setup, WTP transition for specific funds, first-time bAV arrangement) are not included — those are specific to each company's timeline.

All dates are based on 2026 regulatory parameters as published by the relevant supervisory authorities. Regulatory parameters — particularly the UK qualifying earnings thresholds and German BBG figures — are confirmed in Q4 of the preceding year and take effect at the start of the relevant tax or calendar year.

Pensvyne is not a legal or regulatory advisory firm. This calendar is for information purposes. Employers should verify current obligations with qualified pension legal or compliance advisors for their specific circumstances.

Standing obligations: every month

These obligations recur on a monthly basis regardless of other events:

• UK — contribution payment: Pay DC pension contributions to the qualifying scheme by the 22nd of the month following the payroll month (or 19th for non-electronic payment). Covers all enrolled employees.
• UK — assessment at each pay reference period: Assess all workers for eligibility changes at each payroll run. A worker reaching age 22, or whose earnings cross the earnings trigger, must be assessed and enrolled if eligible.
• Germany — bAV Direktversicherung/Pensionskasse contributions: Pay premium contributions to the pension insurer according to the schedule specified in the insurance contract. Most contracts specify monthly payment.
• Germany — BRSG subsidy: Verify that the 15% BRSG subsidy is applied correctly to any employee Entgeltumwandlung in each payroll run.
• Netherlands — pension contribution payment: Pay contributions to the applicable pension provider (bedrijfstakpensioenfonds or insurer) on the schedule specified by that provider. Most require monthly reporting and payment.
• Sweden — Collectum monthly report: Submit monthly salary data for all ITP-eligible employees by the end of each month. Pay ITP1 and ITPK contributions to Collectum by the 12th of the following month.
• Denmark — ATP contributions: ATP is collected through the payroll process and reported via eIndkomst (E-income). ATP contributions are due monthly with payroll.
• Finland — TyEL contributions: TyEL is paid monthly to the designated TyEL insurance company. Monthly reporting to Finanssivalvonta-supervised insurer.

Q1 2026 (January–March)

January 2026

• Germany — BBG update (1 January): The Beitragsbemessungsgrenze (BBG) for 2026 takes effect on 1 January. The 2026 BBG (allgemeine Rentenversicherung, Westdeutschland) is to be confirmed by the German government in Q4 2025. Action: Verify that your pension administration system has updated the BBG figure and recalculate bAV contribution caps accordingly. The §3 Nr. 63 EStG tax-free cap is 4% of the BBG.
• Netherlands — WTP transition check: For any pension fund whose WTP transition date was 1 January 2026 (many large sector funds targeted this date), verify that: (a) payroll systems are calculating contributions on the new WTP franchise and age-neutral premium, (b) new hires are being enrolled into the WTP DC scheme not the legacy DB arrangement, (c) the fund has confirmed the invaren calculation has been processed for all transitioning members.
• Sweden — ITP inkomstbasbelopp update: The IBB (inkomstbasbelopp) for 2026 is announced by Pensionsmyndigheten. ITP1 and ITP2 salary thresholds are based on the IBB. Action: Confirm Collectum or your payroll system has updated IBB-based thresholds for 2026 ITP calculations.
• All — Annual pension parameter audit: The start of the calendar year is the right time to audit all pension system parameters for currency: UK QE thresholds (effective 6 April, but plan ahead), German BBG, Dutch franchise figures, Swedish IBB, Danish ATP rates, Finnish TyEL rates.

February 2026

• UK — annual benefit statement planning: For DC pension schemes, annual benefit statements must be provided to members within twelve months of the end of the scheme year. Plan the production schedule with your pension provider for any scheme years ending Q1 2026.
• Germany — Direktversicherung policy renewal notifications: Some Direktversicherung contracts include annual policy review notifications in Q1. Verify any 2026 premium changes with your insurer and update payroll accordingly.

March 2026

• UK — re-enrolment date review: Companies whose three-year re-enrolment date falls in Q1/Q2 2026 should confirm the re-enrolment schedule. The employer can select a date within a three-month window on either side of the third anniversary. The re-enrolment assessment and re-declaration must be completed within five months of the chosen date.
• Netherlands — OR consultation for WTP changes: If your Dutch pension arrangement requires an OR (ondernemingsraad) consent decision on WTP transition terms, the consultation process should be at an advanced stage by March 2026 for employers targeting a 2026 or early 2027 transition date.

Q2 2026 (April–June)

April 2026

• UK — new tax year (6 April): The 2026–27 UK tax year begins 6 April 2026. Key changes effective this date:
  • New qualifying earnings (QE) thresholds and earnings trigger as announced by DWP. Action: Update your pension administration system with the 2026–27 QE figures immediately on 6 April. Any payroll run after 6 April using 2025–26 figures is calculating on the wrong basis.
  • Any change to the National Insurance rates or thresholds may affect the employer social insurance saving calculation for BRSG-equivalent purposes in cross-border scenarios.
• UK — re-declaration of compliance: If your re-enrolment date was in Q4 2025 or Q1 2026, the re-declaration of compliance must be filed with TPR within five months of the re-enrolment date. Deadlines in Q2 2026 for Q4 2025/Q1 2026 re-enrolment dates.
• UK — annual benefit statement distribution: For schemes with a scheme year ending 31 March, annual benefit statements should be in distribution by end of Q2 at the latest.

May 2026

• Netherlands — UPO distribution deadline: Annual Uniform Pensioen Overzichten (UPOs) must be provided to members. The statutory deadline for UPO distribution is 30 September (for schemes with a December year-end), but pension funds typically distribute in H1. For employers: verify that the pension fund has accurate member data by the data submission deadline (typically April/May), and ensure employees are aware of when to expect their UPO.
• Germany — mid-year BBG check: If the German government has announced any mid-year adjustment (rare but possible in unusual economic conditions), verify current system parameters against official publications.

June 2026

• UK — scheme year reporting: For DC schemes with a June scheme year-end, annual reporting obligations are due within seven months of the year-end (i.e., by January 2027). This is the time to begin gathering the data needed for trustees' annual report and accounts if applicable.
• Sweden — ITP annual reconciliation: Collectum sends an annual reconciliation to employers in H1 confirming total ITP contributions paid vs. contributions due. Review and resolve any discrepancies promptly.

Q3 2026 (July–September)

July 2026

• Netherlands — WTP transition: three-year review: The WTP entered into force on 1 July 2023. Pension funds that have already transitioned should be reviewing their first-year DC scheme performance reports. Employers at companies whose fund transitioned in 2025 should be reviewing the first full-year contribution and investment reports from the new DC arrangement.
• UK — summer re-enrolment window: Companies with staging dates in summer 2023 reach their three-year re-enrolment window in summer 2026. Identify if your company is in this window and confirm the re-enrolment date.

August 2026

• Germany — Betriebsprüfung preparation: German social insurance audits (Betriebsprüfung by Deutsche Rentenversicherung) are typically announced 4–8 weeks in advance. If you receive a notification in Q3, begin preparing bAV records: contribution history for all employees, BRSG subsidy calculations, evidence that contribution rates align with BBG thresholds, leaver vesting documentation.

September 2026

• Netherlands — UPO statutory deadline: Annual UPO distribution to all active members must be completed by 30 September for schemes with a December year-end. Verify with your pension fund that UPOs have been distributed and that any employee who reports not receiving theirs is followed up promptly.
• UK — opt-out window management: Quarter-end is a useful time to review opt-out records: how many employees have opted out since last re-enrolment? What is the current active membership percentage? This data is needed for the re-declaration of compliance when re-enrolment is due.

Q4 2026 (October–December)

October 2026

• UK — Q4 re-enrolment window: Companies with staging dates in Q4 2023 or Q1 2024 enter their three-year re-enrolment window. Confirm whether your company is in this window and set the re-enrolment date.
• Germany — 2027 BBG pre-announcement: The 2027 BBG is typically announced by the German Ministry of Labour and Social Affairs (BMAS) in October or November. Action: Monitor for the announcement and plan the January 2027 contribution recalculation.
• Sweden — 2027 IBB pre-announcement: Pensionsmyndigheten typically announces the following year's IBB in Q4. Monitor for the 2027 IBB announcement.

November 2026

• UK — 2026–27 annual benefit statements: For DC schemes with a September scheme year-end, annual benefit statements are due to members by September 2027. Begin data assembly with your pension provider in November/December for a Q1 2027 production run.
• Netherlands — year-end member data reconciliation: Before year-end, reconcile the member data held by your Dutch pension fund against your HRIS. Any discrepancies in salary, part-time factor, or employment status affect year-end contribution calculations and the accuracy of member records going into 2027.

December 2026

• All — year-end payroll reconciliation: Before the December payroll is finalised, confirm that total pension contributions for 2026 (by employee and employer) match the expected totals based on salary history. Any discrepancy needs to be identified and corrected before year-end — not discovered in January.
• UK — re-declaration of compliance filing deadline: Any re-enrolment date in August 2026 has a re-declaration filing deadline of approximately January 2027 (five months). Flag this for early January if your re-enrolment was in August.
• Germany — final BRSG reconciliation: Confirm that the total BRSG subsidies paid in 2026 are correctly recorded and reconciled with the Entgeltumwandlung amounts for each employee. This record is what the Betriebsprüfung will check.

Irregular / once-per-cycle obligations to track

Beyond the recurring annual calendar, several obligations occur on longer or irregular cycles:

• UK re-enrolment: Every three years from your staging date. Re-declaration filing within five months of re-enrolment date.
• Netherlands WTP transition completion: Statutory deadline 1 January 2028. Most funds targeting 2026 or 2027 transition dates.
• Germany Betriebsprüfung: Deutsche Rentenversicherung audits are typically every four years for most employer sizes. Being audit-ready is a continuous obligation, not a seasonal one.
• Swedish ITP contract review: Collectum periodically reviews registered employer arrangements. Ensure your registration is current and salary data is accurate.
• IORP II pension benefit statement cycle: Annual for active members, as required under Article 40 of Directive 2016/2341/EU. Confirm your pension providers' annual statement schedules for each country.