The Dutch pensions regulator (DNB) has emphasised the difficulty of interpreting the QIS outcomes clearly, arguing that “more impact studies are needed on specific aspects of valuation and solvency capital requirements before conclusions can be drawn.

In a submission to the European Commissioner for Internal Market and Services Michel Barnier, DNB stated that ex-post benefit reductions “appear to be overvalued” given that benefit reduction is a “last resort mechanism” under current Dutch law. It stated that before accrued benefits can be reduced, pension funds need to have tried all other security mechanisms, and to have concluded that recovery is not possible within the existing requirements without reducing benefits. DNB argued that IORPs use "mechanical limits" to indicate when they would need to reduce accrued benefits but stated that this does not take into account the possibility that an IORP may find alternative ways of funding for example through a subordinated loan and therefore will not need to reduce benefits.

The document also argued that the QIS technical specifications in the document did not account for the supervisory framework or for the potential regulatory and supervisory response to certain circumstances. It read: “As yet, there is no supervisory framework connected to the holistic balance sheet. Such a framework is, however, essential in order to determine potential policies on increases in contributions, indexation, reductions in benefits and so on. Given that this QIS started in a period of crisis, a significant number of the possible scenarios would be threatened.”

Holistic balance sheet results were found to be far more inconsistent with current policies than had been expected. The current policies have been set for a system providing 97.5% security, whereas the QIS calculations have been performed with parameters and a solvency capital requirement calibrated to achieve 99.5 per cent security.

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