2024 was characterised by positive investment results, despite the increasing geopolitical risks. For 2025, it is important that we monitor how and whether these risks will escalate, for example the situation in the Middle East. Donald Trump was appointed President of the United States in January 2025. He has already launched various plans, including a reduction in taxes, fuelling fears that the US budget deficit will remain high and will cause government debt to rise further. Trump has also threatened to impose import tariffs on goods from various countries, which could lead to an escalation of trade disputes. Inflation already increased in the United States at the end of 2024 following the announcement of his plans, causing a rise in interest rates. The actual trade tariffs were announced in early April 2025 and these were greater and more extensive than anticipated. Several countries responded by imposing import tariffs on American goods, thereby escalating the trade war, resulting in panic on the financial markets.
Central banks reduced the official interest rates during the course of 2024, and expectations for 2025 are mixed. The European Central Bank (ECB) is expected to further reduce official interest rates, as inflation in the eurozone has reduced and is approaching the 2% target. Economic growth is also moderate in the eurozone, with significant differences between countries. The US Central Bank is expected to be more cautious about lowering official interest rates due to rising inflation and continued strong economic growth.
The International Monetary Fund (IMF) is anticipating global growth of 3.3% in 2025. The American economy is performing better than expected according to the IMF, although it should be noted that there is considerable uncertainty regarding the consequences of plans to increase import tariffs. A growth of 2.7% is forecast for 2025. With respect to the eurozone, the IMF expects a growth of 1.0% in 2025 and with regard to China deflationary pressures and ongoing challenges in terms of domestic demand.
The world is currently facing various geopolitical uncertainties that can have financial consequences. This certainly applies to the war between Ukraine and Russia, the conflict in the Middle East, the tensions between Taiwan and China and the question of how far Donald Trump’s previously announced measures, such as the introduction of import tariffs, will play out in practice. Not only the humanitarian consequences but also the potential economic consequences raise concerns for the pension fund. Any escalation of such conflicts, including those in Ukraine and the Middle East, could negatively impact the economy in various ways. All kinds of investments could be affected if there is a major conflict, which is why the fund is increasing its focus on maintaining a sufficient spread of invested assets (diversification).
The funding level increased slightly in early 2025, partly due to interest rate increases. The funding level was 120.9% by late March and the policy funding level stood at 120.0%. On 2 April 2025, named Liberation Day by Donald Trump, financial markets were taken by surprise by the magnitude and scope of the import tariffs announced by the Trump administration. The announcement led to sharp declines on stock markets worldwide, resulting in a decrease in the funding level. The funding level was 118.8% at the end of April.
In early 2025 and following consultation with the Board, the Social Partners decided to set a transition date of 1 January 2027 in the Transition Plan. There are various reasons for postponing this transition date:
Based on the draft Transition Plan that the social partners shared with the Board, the Board has already taken a large number of decisions in principle about the details of the new pension scheme. This means that the Board can start writing the Implementation Plan and Communication Plan immediately after delivery of the final Transition Plan.
The Board submitted the Data Quality file to DNB in late 2024 for partial assessment. As SPF already started assessing pension administration data quality in 2021, it was unable to use the Dutch Federation of Pension Funds’ Data Quality Framework in the early stages of its assessment and did not adhere to all the specific steps that have since been set out in that framework. This was a reason for DNB to require SPF to go through these steps again. SPF expects to be able to resume the partial assessment in mid-2025. The Board also decided to submit the Risk Appetite file to DNB for partial assessment.
This bill was passed by the House of Representatives on 8 October 2024 and is currently still under review by the Senate. There has been a lot of discussion about the feasibility of the Act, leading the Minister to commission Nibud to conduct a preliminary study regarding a lump sum payment tool. The effective date has also been postponed until 1 July 2026. Several political parties have suggested that this should be postponed until the Future Pensions Act transition is complete. The Board will continue to monitor further developments and ensure that the fund is ready to implement the Act once it enters into force.
Other regulations and legislation
Bill to extend the transition period for future pensions
At the time of writing, the Dutch House of Representatives is discussing the bill to extend the transition period for future pensions. This bill includes various proposals, such as postponement of the deadline for the transition from 1 January 2027 to 1 January 2028. An amendment to this bill was submitted by Agnes Joseph and others, introducing either a referendum or the standard objection procedure for value transfers for the ‘transition’ to the new system. If this amendment is adopted, it could have major consequences for the envisaged Future Pensions Act transition. Advice has, therefore, also been sought from the Council of State on this amendment.
Bill on pension issue commitments
This bill, which is expected to be submitted in the first six months of 2025, will result in changes pledged by the Minister (standardisation of the definition of ‘child’, voluntary continuation of the orphan’s pension) being implemented during the parliamentary process and several technical changes will also be made.
Digital operational resilience regulation for the financial sector - DORA
This regulation harmonises the minimum digital resilience requirements for financial institutions and sets rules to better manage digital risks at external service providers. DORA came into force on 17 January 2025. As the final legislative texts were not delivered until December 2024, pension funds were offered the time and space to complete the DORA implementation in the first six months of 2025.
The sustainability policy is now a fixed item on the Board agenda. The Board will be taking further steps in 2024 with respect to sustainability and ESG. Topics in the planning for 2024 include:
The introduction of the Digital Operational Resilience Act (DORA) in 2025 means that the Board will have to make preparations in 2024, together with the administrator. This not only demands further knowledge development within the Board but also effective monitoring of the management measures by and through DPS.
The Board will start a review of the strategic communication policy in 2025, partly in the light of the transition to the new pension contract.
The changes SPF is facing are substantial and diverse in nature. These partly concern developments relating to pensions, such as the Future Pensions Act, the intensification of communication with members, rising costs and pension market developments. It also concerns geopolitical changes and developments at the employer: SPF members work in the petrochemical industry, a sector that is under pressure in Europe as a consequence of high energy costs and increased regulatory pressure.
At the end of 2025, SPF will start identifying possible scenarios for the future, including conducting a SWOT analysis.