The Dutch WTP Reform: What Changes for Employers in 2026

The largest reform in Dutch pension law since 1952

On 1 July 2023, the Dutch parliament formally adopted the Wet toekomst pensioenen (WTP) — the Future Pensions Act. The WTP represents the most fundamental redesign of the Dutch occupational pension system since the original Pensioenwet entered into force. It requires every Dutch pension fund and insurance-based occupational pension scheme to transition from a collective defined benefit (DB) model to a form of defined contribution (DC) by 1 January 2028 at the latest.

For employers with Dutch employees, the WTP transition is not optional and not distant. Pension funds and insurers must submit transition plans to DNB (De Nederlandsche Bank) and must have completed the transition of all active members by the statutory deadline. This article explains the key changes, the timeline, and what employers practically need to do.

What the WTP changes at the structural level

Under the Pensioenwet (PW) as it existed before the WTP, most Dutch employees belonged to a collective defined benefit scheme — either a bedrijfstakpensioenfonds (sector-wide fund, mandatory for all employers in the sector), an ondernemingspensioenfonds (company-specific fund), or an insurance-based arrangement. The defining feature of these schemes was a collective benefit promise: members accrued pension rights expressed as a percentage of salary per year of service, with the fund collectively managing the assets and bearing the investment risk.

The WTP replaces this collective DB model with two new DC-based contract types:

1. Flexibele Premieovereenkomst (Flexible premium agreement)

The primary new contract type. The employer pays a defined contribution (premie). The contribution is invested in a pension capital account for the individual member. The investment return accrues to the individual. At retirement, the accumulated capital is used to purchase a pension benefit (which may be a variable annuity that continues to participate in investment returns).

Critically, the WTP requires age-neutral contribution rates (leeftijdsonafhankelijke premie) under the flexible premium agreement. Under the old system, older workers had higher contribution rates because they had less time for their contributions to compound. Under the WTP, the same contribution rate applies regardless of age — younger workers benefit more from the compound effect over time, which means they accrue proportionally more pension per euro of contribution.

2. Solidaire Premieovereenkomst (Solidarity premium agreement)

A modified DC approach that retains some collective risk-sharing. Individual pension accounts (projectievermogen) exist but a portion of returns is redistributed among members to provide some protection against investment downturns, particularly for older members nearing retirement. The solidaire variant is typically used by large sector funds that want to maintain some element of collective risk-sharing.

For most employers at companies with 50–300 employees, the relevant contract type will be the flexibele premieovereenkomst, as the solidaire model is primarily implemented at the large bedrijfstakpensioenfonds level.

The transition timeline

The WTP sets out a transition period from the law's entry into force (1 July 2023) to 1 January 2028. Within this window:

• Pension funds and insurers must file a transitieplan with DNB. The exact deadline depends on the fund's size and structure, but most funds filed or were required to file their plan in 2024–2025.
• Employers and employees (or their collective bargaining representatives) must agree on the new pension contract terms before the fund can proceed. This typically means amending the pensioenreglement (pension scheme rules).
• The invaren process — converting existing DB accrued rights into DC-equivalent capital — must be completed by January 2028. Invaren is optional in principle (pension funds can maintain existing DB entitlements separately) but is strongly encouraged by DNB and is the model most funds are following.

What "invaren" means for accrued rights

The invaren process involves converting a member's existing DB accrued entitlements into an equivalent capital amount in their new individual DC account. The conversion uses the pension fund's collective assets and applies a distribution key to allocate shares of those assets to individual members.

For employees, this means that pension rights they accrued under the old DB system — expressed as a percentage of final or average salary per year of service — will be expressed instead as a capital amount in their personal pension account. The capital amount is intended to be actuarially equivalent to the former DB entitlement, but the future pension benefit will now depend on investment performance rather than being guaranteed.

For employers, the invaren process is primarily managed by the pension fund. But employers have obligations to communicate with employees about the transition, ensure that employment terms are updated, and that HR systems reflect the new contribution structure accurately.

The franchise (offset) change

Under the old Dutch system, pension contributions were calculated on salary above a franchise (drempelwaarde) — a threshold below which salary was excluded from pension calculation, broadly aligned with the AOW (state pension) to avoid duplication. The franchise under the old average-salary DB model was approximately €14,000–€16,000 (varying by scheme).

Under the WTP, the franchise in the new DC schemes must be recalculated. Given the change to age-neutral contribution rates and the DC structure, the franchise level changes to reflect the new benefit accrual logic. Employers and pension providers need to update contribution calculation systems to use the correct WTP-compliant franchise figure from the transition date.

This is one of the most common administrative errors in WTP transitions: carrying over the old franchise figure into the new DC contribution calculation, which produces incorrect employee contributions from day one.

The employer's practical obligations in 2025–2026

For an employer whose Dutch employees participate in a bedrijfstakpensioenfonds (which applies to most employees in Dutch industry sectors), the transition is largely managed by the fund. However, the employer has several specific obligations:

1. Update employment contracts or CAO references

The WTP requires that the pension arrangement be documented correctly in employment contracts or the applicable collective agreement (CAO). If your Dutch employees' employment contracts contain a reference to the old DB scheme, these need to be updated when the new DC arrangement takes effect. For companies on a CAO, the update flows through the collective agreement — but the employer should confirm with legal counsel that all employment contracts are aligned.

2. Update payroll contribution calculations

From the transition date for your employees' fund, the contribution calculation logic changes. The new DC premie is age-neutral, the franchise figure changes, and the contribution is expressed as a percentage of pensioengrondslag (the salary above the franchise, up to the maximum pensionable salary). Payroll and HRIS systems must reflect these parameters correctly.

3. Communicate with employees

The WTP places enhanced communication obligations on pension funds, but employers are responsible for ensuring their employees understand what is changing and when. DNB and the pension fund typically provide materials, but HR teams need to distribute them and ensure employees receive the required information.

Specifically, employees must receive a Uniform Pensioen Overzicht (UPO) reflecting their entitlements before and after the transition — the fund handles the UPO itself, but HR should ensure employee data held by the fund is accurate beforehand.

4. Ensure accurate deelnemersadministratie (member records)

The transition is a data-intensive exercise. The pension fund's invaren calculation depends on accurate member records: employment start date, salary history, part-time factors, any breaks in membership. Employers who have maintained poor pension data records will experience friction in the invaren process. Now is the right time to audit the accuracy of data held by your Dutch pension fund against your HRIS records.

5. Handle the transition for new hires

New employees hired after the transition date join the new DC scheme directly — they do not have DB accrued rights to convert. From an administration standpoint, new hires from the transition date onward follow the new contribution structure. But HR systems must be configured to enrol new Dutch employees into the correct DC arrangement and apply the correct WTP contribution parameters.

What changes for employers outside the bedrijfstakpensioenfonds system

For employers that operate outside a mandatory sector fund — either through a company pension fund (ondernemingspensioenfonds) or a direct insurance arrangement (verzekerd pensioen) — the WTP transition is more directly managed by the employer. These employers must:

• Work with their insurer or fund to develop a transition plan
• Consult with works council (ondernemingsraad) — the OR has a formal right of consent (instemmingsrecht) under Article 27 of the WOR (Works Councils Act) for any change to pension arrangements
• File notifications with the relevant supervisor (DNB or AFM depending on the arrangement type)
• Update the pensioenreglement (scheme rules) and employment contracts

The OR consent process adds time to the transition and should be factored into the planning timeline. For a company hoping to complete its transition by mid-2027, OR consultations should begin no later than early 2026.

2026 specifically: what employers should be doing now

By the time this article was published (March 2025), most pension funds had filed or were preparing their transitieplannen. For employers in 2026, the immediate priorities are:

1. Confirm your fund's transition date: Each fund sets its own transition date within the WTP window. Many large funds targeted 1 January 2026; others are targeting 2027. If you don't know your fund's transition date, contact the fund directly or check its communications.
2. Verify your payroll system's WTP parameters: If your fund's transition date is January 2026, your payroll contribution calculation should already reflect the new franchise and age-neutral premie. If it doesn't, contributions have been calculated incorrectly since January 2026.
3. Check that employee data at the fund matches your HRIS: Request a member data extract from your pension fund and reconcile it against your HRIS. Discrepancies in salary figures, part-time percentages, or employment dates will produce errors in the invaren calculation if not corrected before the fund processes the transition.
4. Update HR documentation: Ensure offer letters and employment contracts for new Dutch hires reference the correct WTP-compliant scheme, not the legacy DB arrangement.

What the WTP does not change for employers

It is worth being explicit about what remains unchanged:

• The obligation for Dutch employers to participate in the applicable bedrijfstakpensioenfonds if their sector has a mandatory fund — this obligation persists under the WTP
• The AOW (state pension) provided by the Dutch government — this is not affected by the WTP
• The GDPR obligations for pension data processing between employer and pension provider
• The requirement to report to DNB or AFM for any direct employer-managed arrangements

The transition as an administrative discipline test

The WTP transition is, in practical terms, a stress test of how well an employer has been managing its Dutch pension administration. Companies with accurate, well-maintained member records, clear payroll integration with their pension provider, and documented employment terms will navigate the transition with minimal friction. Companies where pension administration has been handled informally or sporadically will face data reconciliation challenges at the worst possible time — when the fund needs accurate information to complete the invaren calculation.

The transition deadline of January 2028 is the legal outer limit. Most employers should target completion 12–18 months before that date to allow time for data correction, contract updates, and employee communications without compressing the timeline dangerously.

Note: This article provides general information about the WTP reform. Employers should seek qualified legal and pension advice on their specific obligations. Pensvyne is an administration tool and does not provide legal or actuarial advice.