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Future-proof regulatory change for European pension funds

Helping Dutch and European pension funds steer the Wtp transition, IORP II and DORA without losing sight of the participant.

For Dutch pension funds, 2026 is mid-flight in the largest pension reform in a generation. On 1 January 2026, the first major wave of funds, covering roughly 9.5 million workers, moved into the Wet toekomst pensioenen (Wtp), shifting from defined-benefit promises to lifecycle contribution schemes. The next wave follows on 1 January 2027. DNB and AFM are no longer issuing general guidance. On top of Wtp, DORA is fully applicable to pension funds, putting ICT incident classification, third-party risk and digital resilience squarely on the board agenda. The IORP II review is forming. SFDR Level 2, ESG reporting and stewardship expectations are tightening. The AI Act’s high-risk regime reaches advice, communication and member-segmentation models from August 2026. Together, they sit on top of a transition that consumes the same scarce risk, actuarial, IT and operations capacity.

The 2026 pension landscape: mid-flight in a generation-defining transition

For Dutch pension funds, 2026 is mid-flight in the largest pension reform in a generation. On 1 January 2026, the first major wave of funds, covering roughly 9.5 million workers, moved into the Wet toekomst pensioenen (Wtp), shifting from defined-benefit promises to lifecycle contribution schemes. The next wave follows on 1 January 2027, with full compliance for all parties required by 1 January 2028.

DNB and AFM are no longer issuing general guidance. They are live-supervising implementation plans, communication plans, transition decision-making, valuation, balance treatment and the operational data quality that everything else depends on. The supervisory dialogue has moved from “explain the design” to “show me the controls”.

On top of Wtp, DORA is fully applicable to pension funds, putting ICT incident classification, third-party risk and digital resilience squarely on the board agenda. The IORP II review is forming. SFDR Level 2, ESG reporting and stewardship expectations are tightening. The AI Act’s high-risk regime reaches advice, communication and member-segmentation models from August 2026. Each programme alone is manageable. Together, they sit on top of a transition that consumes the same scarce risk, actuarial, IT and operations capacity.

How ACE + Company helps

Two distinct offerings. ACE consulting, on the ground, in focused teams. And ACE Regulatory AI, our regulatory intelligence platform.

ACE consulting

A boutique change management practice with niche regulatory expertise in the European financial sector. Strategic and tactical services on the change programmes that have to land.

  • Regulatory change is the only thing we do. Structuring, orchestrating and implementing new regulations is the practice, not a sideline. Niche regulatory expertise runs through every engagement.
  • Change management as a discipline. A proven track record in change management in complex environments. We work in behaviour, governance, controls and stakeholder alignment, not just gap analysis.
  • Lean teams that integrate with yours. A focused team pairs with your legal, compliance, operations and product owners, transferring capability as we go.
  • Sustainable capabilities, lasting impact. Every engagement is engineered for the day after we leave. Documentation, controls, MI, training and ownership are designed in from day one, so the post-transition control environment is auditable and stable.

Working alongside Dutch and European pension funds on the regulatory change agenda set by Wtp, DORA, IORP II, SFDR and DNB / AFM dialogue.

ACE Regulatory AI: our regulatory intelligence platform

RegAI reads regulatory texts, structures binding obligations, and maps them to your control framework, so you know where you stand on the regulations you onboard.

  • Nexus. A cross-regulation view, organised by operational domain and topic family rather than by document. The groups you actually own (DORA, governance, ICT risk, third-party risk, sustainability, member communications and so on) pulled together across the regulations onboarded for your firm, rather than read in document silos.
  • Posture. Defensible coverage by regulation and by domain, computed continuously from real artifact-to-requirement evidence. Not a self-assessed RAG. Numbers your board and your supervisor can both understand.
  • Pulse. Regulatory change monitoring that tells you what it means for you. When DNB or AFM publishes new Q&A or guidance, Pulse identifies which of your obligations are affected and shows the impact on your live posture.
  • Workbench. Close gaps in the same place you find them. Upload a new policy or amend an existing artifact, preview the projected posture change before approving, and leave a complete audit trail.
  • Mathilda. Your AI compliance assistant. Ask “How well are we covered on DORA Article 5?” in plain English and get a board-ready answer in seconds, with article references and suggested follow-ups.

RegAI’s library spans core EU financial regulations including DORA, GDPR, MiFID II, NIS2 and others, with the architecture to add further regulations and jurisdictions over time.

What you can plan around

  • A defensible Wtp transition position you can present to DNB, AFM or your board, backed by auditable evidence rather than self-assessed RAG.
  • A coordinated response across Wtp, DORA, IORP II and SFDR so the same control answers multiple supervisors instead of being rebuilt for each one.
  • Lower cost of regulatory change. Your most experienced risk, actuarial and operations people focus on judgement, not on summarising the same materials a fifth time.
  • A control environment that holds after we leave, embedded in your operating model from day one.
  • A live view of how your post-transition compliance position evolves as DNB and AFM expectations sharpen.

Future-proof your 2026 pension fund agenda

Whether you transitioned in January, are preparing for a 2027 invaringsmoment, or are stress-testing your post-transition control environment, we would like to talk.

Talk to us More about RegAI