The Dutch Federation of Pension Funds (Pensioenfederatie) has raised strong concerns about the Ministry of Social Affairs and Employment’s consultation on a proposed temporary scheme to compensate people whose WIA benefits were incorrectly calculated, warning that the approach risks leaving disabled pension scheme members worse off.

In its consultation response, Pensioenfederatie said that while it supports efforts to ensure people receive what they are entitled to, the proposed regulation fails to address knock-on effects for supplementary disability pensions and premium-free pension accrual.

These elements are often directly linked to the WIA daily wage and are therefore also affected by errors made by the Employee Insurance Agency (UWV), it argued.

Under the proposal, UWV would be able to correct past errors in the WIA daily wage through a one-off financial compensation.

However, the federation argued that the scheme only resolves issues within UWV itself and does not extend to pension funds, despite the fact that many WIA recipients also receive an occupational disability pension and accrue pension rights without paying contributions.

According to the federation, UWV's recovery actions do not occur in isolation and often have direct consequences for pension funds.

Indeed, it warned that this could create situations in which a corrective payment by UWV does not trigger benefit recovery, while a corrective payment by a pension fund does, potentially leading to adverse tax or benefits consequences for vulnerable participants.

Pensioenfederatie also criticised the lack of provision for historical data sharing.

It said pension funds require corrected historical WIA data from UWV to retrospectively adjust their administration and ensure members receive their full entitlements.

Without this information, funds may be unable to act or may be forced into complex manual corrections, increasing operational risk and costs.

In addition, the federation expressed concern about what it described as insufficient central direction at UWV.

It called on the Ministry of Social Affairs and Employment and UWV to reassess data provision to pension funds and to establish a more coordinated, chain-wide approach, potentially through a joint steering group involving all affected parties.

“The pension sector finds it essential that people receive what they are entitled to,” the federation concluded, warning that without changes to the proposal, disabled pension participants risk “falling between the cracks” of the recovery process.

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