On 14 december 2023, DNB published a Q&A addressing whether a pension fund, which is in a recovery situation by the end of 2023, needs to submit a recovery plan in 2024 if it expects to submit a bridging plan in 2024.
Question: Should a pension fund that is in a recovery situation at the end of 2023 submit a recovery plan in 2024 if it expects to submit a bridging plan in 2024?
DNB answers that if a pension fund is in deficit without an approved bridging by the end of 2023, it must submit a feasible recovery plan to DNB within three months. However, if a pension fund obligated to submit a recovery plan intends to submit a bridging plan in the same year, it may, under certain conditions, opt out of submitting a recovery plan through the statutory reporting to DNB, please also note Event ID#24238. The law requires the recovery plan submission deadline in 2024 to precede the bridging plan deadline.
The conditions are as follows:
– Reporting obligation:
The pension fund must notify DNB by 1 April 2024, stating its intention to submit a bridging plan by 1 July 2024. This notification is done via email to herstelplan@dnb.nl and it doesn’t apply if the pension fund submits a bridging plan for 2024 to DNB before 1 April 2024, or if it already has an approved bridging plan for 2023.
– Submission of recovery plan if no bridging plan is filed:
If the pension fund ultimately decides not to submit a bridging plan by 1 July 2024, and has not submitted a recovery plan, it must then submit a recovery plan by 1 October 2024.
Dient een pensioenfonds dat ultimo 2023 in een herstelsituatie verkeert in 2024 een herstelplan in te dienen als het in 2024 een overbruggingsplan verwacht in te dienen? [Q&A]
ID
26258
Other Features
budget
fixed income funds
notifications
pension funds
recovery
reporting
Date Published: 2023-12-14
Regulatory Framework: Pensioenwet (Pw)
Regulatory Type: Q&As
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