Cyber resilience and the transition to the Future Pensions Act will again be the two central themes of De Nederlandsche Bank’s (DNB) supervision in 2026, as confirmed in the regulator’s newly published supervisory calendar for pension funds and premium pension institutions (PPIs).

The annual calendar outlines the supervisory activities planned for the year ahead, though DNB noted these may be supplemented as developments arise during the pension transition.

The authority also stressed that the significant workload associated with the Future Pensions Act has been explicitly factored into its 2026 planning.

DNB said supervision in 2026 will continue to focus heavily on ensuring a “smooth and careful transition” to the new pension system. Preparations are expected to peak next year, with many funds planning to shift to the new framework on 1 January 2027.

“This will require considerable effort on the part of both the pension sector and DNB,” the regulator said.

Furthermore, DNB will continue its dialogue with the sector regarding planning and practical bottlenecks, engaging through account supervisors, roundtables and its Pension Seminar.

It will also maintain risk-based follow-up on findings identified at funds that have already been phased in, while simultaneously taking steps to organise regular post-transition supervision. Policy statements related to the transition are available through the Future Pensions Act transition collection page in the Open Book Supervision.

Alongside the transition, cyber resilience remains a key supervisory priority. With the Digital Operational Resilience Act (DORA) now in force, European law embeds requirements for managing information security, cybersecurity and outsourcing risks.

DNB’s priorities for 2026 include ensuring IT and cyber risk management, including risks linked to outsourced ICT services, aligns with DORA; maintaining a clear view of ICT concentration risks in outsourcing chains using information registers submitted by institutions; and obtaining deeper insight into signals emerging from threat analyses, incident reports and the SBA Cyber Resilience 2026 analysis.

The regulator said it will undertake further investigations at selected pension funds and pension administrators through risk assessment interviews and deep-dive reviews, and will continue to host seminars and roundtable discussions on the topic.

Pension funds and PPIs can access the full 2026 supervision calendar via the Mijn DNB portal. The inspection calendar for pension administration organisations (PUOs) is also available there.

DNB noted that supervisory themes for pension funds also affect pension administration organisations (PUOs), which may result in direct investigations at PUOs or in pension funds forwarding relevant questions to their administrators.

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