Your member moved abroad and forgot their pension. What will you be able to show from 2027?

A guide for Dutch pension funds, administrators and boards on members abroad you can no longer reach: what changed on 27 October, why this group drops out of view, and how to show you made the effort.

The short answer

A Dutch old age pension must start no later than five years after the member reaches AOW age. If it starts later, the full value is taxed at once, and on top of that 20% revisierente (a penalty interest charge) is due in principle. The Fiscale verzamelwet 2027, adopted by the Eerste Kamer on 27 October 2026, allows those consequences to be waived in certain cases. As an example of a condition, the explanatory memorandum names that the pension provider has tried to contact the person entitled.

For a fund, that means how you try to reach a member abroad, and what you record about it, may soon make a real difference for that member. It makes sense to prepare for it now.

What changed on 27 October

The Tweede Kamer adopted bill 36938, the Fiscale verzamelwet 2027, on 6 October 2026. The Eerste Kamer followed on 27 October 2026. The law takes effect from 1 January 2027.

One part deals with a problem every fund knows: the pension that does not start on time. The rule so far:

An old age pension must start no later than five years after the employee reaches AOW age.

If it does not, the value of the whole old age pension is taxed immediately, and on top of that revisierente of in principle 20% is due. The same applies to partner and orphan pensions.

The explanatory memorandum works this through with a recognisable case: a member who moved abroad and forgot their pension. Tax and revisierente can then add up to 69.5% in total: 49.5% income tax and 20% revisierente. The government adds, in its own words, that the tax consequences are "not fair in all cases" (niet in alle gevallen billijk).

That is why those consequences can now be waived under conditions. The conditions will be set by ministerial regulation. The memorandum gives two examples:

• The person entitled must still be alive when the pension is requested.
• The pension provider has tried to contact the person entitled.

If heirs of a deceased member request a pension that never started, the tax consequences still apply.

What this means for you. The second condition sits with you, not with the member. What "tried" means exactly, and how you show it, is not yet settled. But a fund that records its efforts today, per member, with date and result, is in a strong position once the regulation arrives.

Why members abroad drop out of view

A member living in the Netherlands finds their pension fairly easily. A former member abroad gets stuck in three places.

1. Mijn Pensioenoverzicht sits behind DigiD. The overview shows the AOW and workplace pensions together, but only with DigiD or a European login (eIDAS), and there is no paper route. Applying for DigiD from abroad requires a citizen service number (BSN). Through the SVB it is only open to people who already receive AOW or have had a letter about their first AOW payment. Someone who left long before AOW age often sees their pension nowhere.
2. The address goes stale. People who leave often move again later. The RNI, the register of non-residents, has been fully operational since the end of 2016 and helps funds when someone leaves the Netherlands. But a register is only as good as the last change that reached it. An address that changes in Poland, Portugal or Morocco does not find its way there by itself.
3. Nobody is looking. Agency workers, seasonal workers, drivers and care staff sometimes built up a few years of pension and left. Many do not know it exists. A letter to an old address does not arrive; a letter in Dutch is not read.

How large this can be, ABP showed in 2022: it held no address for 19,000 pensioners, with about 300 million euros of benefits between them. Many had moved abroad.

The Wtp makes it more urgent

Funds have until 1 January 2028 to complete the move to the Wet toekomst pensioenen, the new Dutch pension system. During that transition every member receives letters about their pension. Letters to addresses abroad come back, or reach someone who moved out long ago. Who you cannot reach during the transition stays out of reach after it. Clean records for former members abroad are not a side issue; they are part of a careful transition.

What BRP and RNI do, and do not do

The BRP (the municipal population register) and the RNI remain the foundation. We see them as the first step, not the last. They work well for people who deregistered properly and rarely move afterwards. They work poorly for:

• people who left before the RNI was operational, or never deregistered properly;
• people who moved abroad again without telling anyone;
• partners and children of deceased members whom nobody knows by name;
• people known to the fund under a different name or spelling from the one they use in their country now.

For that group you need further steps. Every further step should add to BRP and RNI, never replace them.

What "tried to contact" could mean: a workable ladder

Below is how we would set it up. This is our proposal, not a legal standard. What the regulation will ask is for the minister to decide.

Two rules make such a file strong:

• Nothing counts on a single lead. Only two independent confirmations turn a lead into a result.
• "Not found" is an outcome too. Record what you tried. That is exactly what shows you tried.

How PensionHunter helps funds

We work on the side of people who worked abroad, so we know the way back: which countries, which languages, which institutions, which employers and what became of them. For funds we put that to work in three ways.

1. GPFR, the Global Pension Finding Register. Free for funds. People who worked abroad leave a contact address for their pensions in GPFR, once. Funds can join free of charge and search for members they cannot reach. Name, date of birth and any national number are turned into one way codes; matching compares codes only, for the same country and overlapping years. Nothing is shared without a yes from the person and from the fund, and a member of the fund's staff confirms every match. Matching starts as funds join. Those who join early help shape how it works.
2. The public notice. Free for funds. A public page on which your fund says, in its own words, that it is looking for former members abroad: in Dutch, English and your former members' languages, with your own contact route. You receive visits per language for your file. A notice goes live only after your written approval of the text.
3. Targeted tracing of members abroad. For the members who remain after BRP and RNI. Under a data processing agreement, with only the data needed and without BSN, bank details or amounts. How we work:

• In groups, not one by one. Members who worked for the same employer, through the same agency or in the same period are one piece of research with many answers.
• Employer and agency first. That is often where the home address at hiring and a contact in the home country sit.
• Then the country itself. Public records there and the network of former colleagues. We do not consult closed population registers.
• Always in your name. Contact goes out with your text and your sender. We never tell anyone other than the member that a pension exists.
• A file per member: reached, located but not reachable, deceased, or not found, with where we searched and the date. Exactly the kind of record the ladder above asks for.

We add to your own tracing and to BRP and RNI. We do not replace them.

Board checklist

• Do we know how many former members have an unknown or foreign address?
• Do we know how many of them fall within five years of their AOW age, or are already past it?
• Do we record every attempt to reach a member, with date, channel and outcome?
• Do we do more than BRP and RNI, and can we show what?
• Do our letters reach members in their own language?
• What do we do with Wtp letters that come back from abroad?
• Do we have a route for partners and children of deceased members abroad?
• Who in the fund owns this file?

Questions funds ask

Has the penalty for a late start been abolished?

No. The rule stays that an old age pension starts no later than five years after AOW age. What is new is that the tax consequences can be waived under conditions, which will follow in a ministerial regulation.

From when does this apply?

The Fiscale verzamelwet 2027 takes effect from 1 January 2027.

Will a fund have to show it tried to reach the member?

The explanatory memorandum names, as an example of a condition, that the provider has tried to contact the person entitled. How that is filled in is for the regulation. Recording what you do is sensible either way.

Does the relief extend to heirs?

No. If heirs of a deceased member request the pension, the tax consequences still apply.

Does GPFR cost the fund anything?

No. GPFR is free for people and free for funds and trustees.

Does PensionHunter receive a list of members?

Not for GPFR: searches use one way codes. For targeted tracing, only under a data processing agreement, with the minimum data needed.

Talk to us

Want to see what this looks like for your fund? We are happy to start small: a pilot with part of your former members abroad, so you see what it delivers before you decide anything more.

See what we do for pension funds or email hello@pensionhunter.ai.

Funds that want to help former members abroad come forward themselves can find GPFR here: pensionhunter.ai/register.

We identify and help you reach people. We give no financial or legal advice.

The PensionHunter Team