The SIVI Standard: Harmonising Pension Fund Data in the Netherlands and Illuminating a Path for Europe

The Dutch pension system, long recognised for its robustness, is undergoing its most significant overhaul in decades with the implementation of the Wet toekomst pensioenen (Wtp). This reform, primarily shifting from collective Defined Benefit (DB) to individualised Defined Contribution (DC) schemes, is creating an unprecedented surge in the volume and complexity of data exchanged between pension administrators and asset managers. In response, the Dutch pension industry, spearheaded by the Pension Federation, has proactively introduced the SIVI All Finance Standard (SIVI AFS). This standard provides a uniform set of data definitions and structures for reporting on investments and performance, specifically at an aggregated cohort level, thereby excluding sensitive personal data.

Early adopters like APG, a major Dutch pension administrator, report significant benefits, including easier data integration and reduced manual reconciliation. SIVI’s governance, with ownership by the Pension Federation and maintenance by the SIVI organisation, ensures industry alignment and a demand-driven evolution of the standard. Beyond its immediate utility in the Netherlands, SIVI’s pragmatic design, clear data scoping, and collaborative governance model offer valuable lessons for other European nations grappling with similar pension reforms and the broader challenge of financial data harmonisation. 

As European Union initiatives like the Financial Data Access (FIDA) framework and EIOPA’s efforts towards regulatory harmonisation gain traction, the SIVI standard emerges not only as a solution to national needs but also as a potential blueprint for fostering a more efficient, transparent, and resilient European pension data ecosystem. This report delves into the intricacies of the Wtp, the structure and benefits of SIVI, its governance, and its potential implications for the wider European landscape, positioning data standardisation as a critical enabler for the future of pension administration.

The SIVI Standard: Harmonising Pension Fund Data in the Netherlands and Illuminating a Path for Europe

1. The Netherlands’ Pension Landscape in Flux: The Wtp Catalyst for Data Revolution

1.1. Context: The Esteemed Dutch Pension System Faces Transformation

The Netherlands has consistently been lauded for operating one of the world’s premier pension systems, characterised by its strong emphasis on collective risk-sharing and substantial capital-funded assets. For many years, this system has provided a high degree of retirement income security. The Dutch occupational pension fund system is the largest in the European Union, with assets under management exceeding €1.5 trillion, and total pension assets surpassing 200% of the nation’s GDP. This significant scale means that any reforms undertaken in the Netherlands not only have profound domestic implications but are also closely watched by other European nations facing similar demographic and economic pressures. The very strength and size of this system make the current wave of reforms particularly noteworthy.

1.2. The Wet toekomst pensioenen (Wtp): A Paradigm Shift

After nearly fifteen years of debate, the Wet toekomst pensioenen (Wtp), or Future of Pensions Act, received final approval and entered into force on July 1, 2023. This legislation marks the most extensive reform of the Dutch pension system to date, ushering in a transition period for social partners, employers, and pension providers that extends until January 1, 2028. The Wtp is designed to create a pension system that is more sustainable, personal, and transparent.

At its core, the Wtp mandates several fundamental changes:

  • Core Change 1: DB to DC Transition: The most significant change is the mandatory shift from predominantly Defined Benefit (DB) pension schemes to Defined Contribution (DC) schemes. Under the old DB system, participants were typically promised a certain level of pension income based on salary and years of service. In the new DC framework, pension outcomes will become more directly dependent on the contributions made and the investment returns generated on those contributions. This transition fundamentally alters the risk profile for participants, moving away from certainty of outcome towards a system where individual investment performance plays a crucial role.
  • Core Change 2: Individual Pension Pots: The Wtp requires a transition from large, centralised pension funds collectively shared among all customers of a provider to individual pension pots for each participant. This makes pensions “more personal,” allowing for investment strategies that can be better tailored, for instance, to different age cohorts. Younger groups, with a longer time horizon to retirement, might opt for different risk profiles than those closer to retirement age.
  • Core Change 3: Age-Independent Premiums: In the new DC schemes, premium contributions will become age-independent, meaning each participant, regardless of age, will have the same premium percentage applied (a flat-rate premium). The maximum standard premium is set at 30% of the pensionable salary, although a higher rate up to 33% may be allowed for compensation purposes during the transition. While simplifying one aspect of contribution calculation, this change still necessitates careful data management to track and allocate these flat-rate contributions across diverse cohorts within the new system.

 

These reforms are not merely financial or structural; they represent a fundamental re-architecting of the pension information flow. The move from collective DB schemes, where calculations could be performed at an aggregate level, to individualised DC pots directly causes the need for more granular, frequent, and complex data exchanges. Each individual pot’s value will fluctuate with contributions and investment returns, requiring a level of tracking and reporting far exceeding previous norms.

 

1.3. The Wtp’s Impact: A Surge in Data Exchange Requirements

The transition to DC schemes and individual pension accounts, as mandated by the Wtp, is set to dramatically intensify the data exchange between pension administrators, who are responsible for managing these individual accounts, and asset managers, who oversee the investment of pension capital. The new system requires a much closer and more dynamic alignment between the fund assets managed by fiduciary managers and the collective administration of these newly individualised pension accounts.

Several aspects of the Wtp directly contribute to this surge:

  • Individualised Tracking: As explicitly states, “Since each participant has their own personal reserved capital account balance, and allocation rules are set per age cohort, the link and data exchange between the pension administrator (participant administration) and asset management (investment administration) will differ from the current model.” This highlights a new layer of complexity in linking investment performance back to cohorts or even individual accounts.
  • Transparency and Governance: A core tenet of the Wtp is to enhance transparency and governance within the pension sector. This inherently requires more detailed and accessible data trails to demonstrate how contributions are managed and how investment returns are allocated.
  • Investment Choices: The Wtp allows for participants to have more choice in how their pension assets are invested, depending on the type of pension agreement. Pension providers will, therefore, need to offer different investment profiles and ensure sufficient flexibility to meet individual preferences and risk profiles. Managing these choices and reporting on their performance necessitates sophisticated data exchange.
  • Regulatory Scrutiny: The Wtp itself has prompted pension funds and providers to undertake a thorough analysis of “how data will be exchanged”, signalling a recognition at the highest levels that existing data infrastructures may not be adequate for the new demands.

 

The Wtp, while aiming for a more sustainable and personal pension system, inadvertently creates a massive data management challenge. This underscores a broader theme often observed in financial services reform: regulatory changes, however well-intentioned, frequently carry significant, and sometimes underestimated, data infrastructure implications. Without a harmonising standard to manage this data deluge, the Dutch pension system would face the risk of operational inefficiencies, increased error rates, and escalating costs in its efforts to implement the Wtp. The following table outlines key Wtp provisions and their direct impact on data exchange needs:

Table 1: Key Wtp Reform Drivers for Increased Data Exchange

Wtp Provision

Implication for Data Exchange

Shift from Defined Benefit to Defined Contribution

Need for individualised (or cohort-based) investment return tracking and reporting; data on contributions directly linked to individual accumulation.

Individual Pension Pots

Granular data required for each participant’s pot, including contributions, investment allocations, and performance.

Age-Independent (Flat-Rate) Premiums

Standardised data on contribution amounts per participant, facilitating consistent processing across different age groups under the new rules.

Multiple Investment Profile Choices

Data to support participant choice architecture, track allocations to different profiles, and report performance specific to each chosen investment strategy.

Increased Transparency & Governance Mandates

Requirement for detailed, auditable data trails for all transactions, allocations, and communications related to pension pots.

This escalating complexity and volume of data exchange, driven by the Wtp’s core tenets, set the stage for the emergence of a new standard designed to bring order and efficiency to this evolving landscape.

2. Introducing SIVI: A Standard for a New Era of Pension Data Exchange

2.1. The Industry’s Proactive Response: The Genesis of SIVI

Recognising the profound data management challenges posed by the Wtp’s intensified data flow requirements, the Dutch pension industry took a proactive stance. Led by the Dutch Pension Federation (Pensioenfederatie), a key representative body for pension funds in the Netherlands, the sector anticipated the need for a common language and framework to manage the impending increase in data traffic. This foresight led to the development and introduction of the SIVI All Finance Standard (AFS) as a collaborative, industry-wide effort to streamline and simplify the necessary data exchange between pension administrators and asset managers. As one report notes, “To simplify this process, the SIVI standard has been developed”. This initiative represents a significant step by the industry to preempt potential operational bottlenecks and inefficiencies that could arise from uncoordinated, bilateral data exchange arrangements in the new pension environment.

This proactive approach by the Dutch pension sector is noteworthy. Often, data standards emerge reactively, in response to crises or market disruptions that expose critical gaps in data transparency or interoperability. The SIVI initiative, however, was born out of an anticipation of future needs catalysed by regulatory reform. Such foresight can lead to smoother transitions, potentially lower implementation costs for the industry as a whole, and the establishment of a more robust and efficient system from the outset, offering a model for how other sectors or countries might approach similar large-scale transformations.

 

2.2. SIVI AFS: Core Purpose and Objectives

The SIVI All Finance Standard (AFS) is designed with a broad and ambitious vision: to form the foundational layer of a dynamic, flexible, and interconnected digital ecosystem within the entirety of the Dutch financial services industry. Its overarching objective is to empower all parties within the financial chain—from insurers and intermediaries to banks and pension providers—to optimally support their customers through streamlined processes and enhanced interoperability. SIVI AFS aims to foster an environment where various distribution models can flourish, operational costs related to data exchange are reduced through the adoption of open standards, and market opportunities can be more effectively optimised.

Within this broad ecosystem, SIVI AFS has a specific and critical role in the pension sector. In the context of the Wtp reforms, its primary purpose is to simplify, standardise, and streamline the increasingly complex information exchange that must occur between pension administrators (who manage the individual pension accounts) and the asset managers (who are responsible for investing the pension capital). The standard focuses on creating a common understanding and format for data related to investments and their performance.

The SIVI AFS documentation outlines a clear focus on three key areas to achieve its ecosystem vision:

  • Customer: Ensuring optimal customer service and experience across different distribution forms and financial products.
  • Data: Facilitating good access to necessary data and enabling secure and efficient data sharing when required.
  • Distribution Chain: Promoting strong interoperability within the financial services chain while accommodating the diverse needs and operational models of its participants.

 

This ecosystem approach suggests a vision that extends beyond simple point-to-point data exchanges for pension administration. While the immediate impetus for SIVI’s application in the pension sector is the Wtp, the underlying SIVI AFS framework is designed to be much broader, encompassing other financial domains like insurance, mortgages, and loans. 

This implies a potential future where pension data, appropriately aggregated and anonymised, could interact within a larger financial data ecosystem, possibly enabling more holistic financial planning tools or integrated services for pension participants, contingent on robust privacy safeguards and participant consent where applicable. Thus, SIVI is not merely a tactical solution to the Wtp’s data challenges but a strategic building block for future innovation across the Dutch financial landscape.

 

2.3. SIVI’s Guiding Principles for Standardisation

To achieve its objectives, the SIVI AFS is guided by five core principles that underscore its pragmatic and adaptable approach to standardisation:

  1. Focus on coherence of standards within the ecosystem: Ensuring that SIVI AFS works harmoniously with other relevant standards and practices.
  2. Emphasis on easily deployable standards: Prioritising practical applicability and ease of implementation for all parties.
  3. Consideration for investments already made: Recognising that organisations have existing systems and seeking to minimise disruption and leverage prior investments where possible.
  4. Targeted support for both analysts and developers: Providing clear documentation and tools that cater to the needs of both business and technical users involved in implementation.
  5. Connection to current technology: Ensuring the standard is compatible with modern technological frameworks and can evolve with technological advancements.

 

These principles indicate a commitment to developing a standard that is not only technically sound but also practical, user-friendly, and economically viable for the industry to adopt. This approach aims to foster widespread acceptance and ensure the long-term relevance of SIVI AFS in a rapidly evolving financial services environment.

3. Deconstructing SIVI: Core Components and Data Governance

3.1. Accessible Explanation of SIVI’s Structure

At its heart, the SIVI standard provides a “uniform set of data tables and fields that all parties agree to use for reporting on investments and performance”. This fundamental agreement on structure is what enables streamlined communication. As Wouter Köbben of APG described, “There’s a uniform structure that ensures everyone uses the same tables and enters specific data in predefined fields”. This eliminates the ambiguity and conversion errors that arise when parties use disparate, proprietary formats.

The technical foundation of this uniformity is the SIVI All Finance Standard (AFS), which incorporates the All Finance Data Catalogue (AFD). The current version is AFD 2.0. The AFD is structured around several key building blocks:

  • Entities and Attributes: SIVI AFS defines various “entities,” which represent core concepts in financial services. For the pension domain, key entities include ‘pension’, ‘investment’, ‘party’ (representing an individual or organisation), and ‘policy’. Each entity possesses a set of “attributes,” which are the specific data fields associated with that entity. For example, the ‘pension’ entity serves as a container for various pension-related data elements. Within this, an entityType such as pensionDetails might include attributes like effectiveDate (the date the pension detail is effective), pensionType (e.g., old-age pension, survivor’s pension), and accruedAmountAfterRetirement (the pension amount accrued after retirement). Similarly, an ‘investment’ entity would hold attributes pertinent to describing an investment.
  • AFD 2.0 Online: To ensure accessibility and clarity, SIVI provides an online tool called “AFD 2.0 Online”. This publicly available data catalogue allows users to consult the complete and up-to-date list of all defined entities, their types, and their associated attributes. It facilitates searching the data catalogue, for example, to find corresponding attributes from older AFD versions or to understand which attributes can occur under a specific entity type. This transparency is crucial for analysts and developers working to implement the standard.
  • Technical Specifications for Implementation: Beyond the conceptual data model, SIVI provides concrete technical specifications to aid implementation. The “Standaard Data-uitwisseling Vermogensbeheer en Pensioenuitvoering” (Standard Data Exchange Asset Management and Pension Execution) offers detailed documentation, JSON (JavaScript Object Notation) schemas, and example messages. These resources, often available via platforms like GitHub, provide developers with the practical tools needed to build compliant interfaces and data exchange processes. The availability of such detailed technical specifications indicates a developer-friendly approach, aiming to lower implementation barriers and facilitate smoother adoption by technical teams. This pragmatic provision of resources is key for translating a standard from a theoretical concept into a working reality.

 

3.2. Data Scope: What SIVI Covers and Excludes for Pensions

A critical aspect of the SIVI standard, particularly in the context of pension data, is its clearly defined scope regarding what information is exchanged and, just as importantly, what is not.

  • Covered Data: The primary focus of SIVI for pension fund data exchange is on “aggregated cohort-level investment data” and “investment performance results”. This encompasses the operational data necessary for pension administrators to understand how assets are invested by their managers and for asset managers to report back on the performance of those investments. The data is structured to facilitate the monitoring of pension fund investments and the sharing of performance metrics relevant to specific groups or cohorts of participants, rather than individuals. As stated in one source, “the SIVI standard only applies to the data needed to facilitate pension fund investments and to share investment performance results”.
  • Excluded Data: The standard deliberately excludes certain types of information to maintain privacy, security, and focus:
  • Personal Data: Crucially, SIVI does not cover the exchange of personal data of individual pension participants. This means that information such as names, addresses, citizen service numbers (BSN), or specific individual account balances are outside the scope of this particular data exchange standard between administrators and asset managers. This design choice is fundamental for ensuring compliance with privacy regulations like GDPR and for building trust among participants and stakeholders. This explicit exclusion of personal data and the focus on aggregated cohort-level information is a strong indicator of a “privacy by design” approach, preempting many potential data security and privacy objections and making the standard more readily adoptable in a heavily regulated environment.
  • Strategic and Policy Information: The SIVI standard is not intended for the exchange of overarching investment strategies, detailed financial frameworks, or specific allocation rules agreed between a pension fund and its asset manager. Such high-level policy and strategic documents are typically exchanged through other means, separate from the operational data flows governed by SIVI.

 

The following table provides an overview of the data scope within the SIVI All Finance Standard as it pertains to pension fund data exchange:

Table 2: SIVI All Finance Standard – Pension Data Scope Overview

Data Category

SIVI Coverage Status

Rationale/Example

Investment Holdings

Covered at Aggregated Cohort Level

To allow pension administrators to monitor asset allocation and exposures for different participant cohorts (e.g., by age group or risk profile).

Investment Performance Metrics

Covered at Aggregated Cohort Level

For calculating and reporting cohort-specific investment returns and benchmarks.

Aggregated Transaction Data

Partially Covered (Aggregated for investment purposes)

Aggregated cash flows, subscriptions, redemptions necessary for investment administration at a cohort level.

Individual Participant Identifying Data

Not Covered

Personal data such as names, BSN numbers, specific individual balances are explicitly excluded to protect privacy.

Individual Participant Transaction Data

Not Covered

Specific contribution amounts or withdrawal details for an identifiable individual are outside this standard’s scope.

Investment Strategy & Policy Documents

Not Covered

Overarching strategic agreements, mandates, and allocation rules are exchanged outside of SIVI’s operational data flow.

Pension Fund Governance & Internal Controls

Not Covered

Information related to the internal governance structures or compliance frameworks of the pension fund or asset manager.

This careful delineation of scope ensures that SIVI facilitates the necessary operational data exchange for efficient pension investment management and reporting while rigorously upholding data privacy principles.

 

3.3. Governance: Ownership by the Pension Federation, Maintenance by SIVI

The SIVI standard’s governance structure is a key element contributing to its credibility and industry acceptance. It is characterised by a clear division of roles:

  • Ownership by the Dutch Pension Federation (Pensioenfederatie): The SIVI standard, as it applies to pensions, is formally owned by the Dutch Pension Federation. The Pension Federation is the umbrella organisation representing the vast majority of pension funds in the Netherlands and is a highly respected voice in the industry. This ownership by an industry body that represents the primary users (the pension funds themselves) ensures that the standard is developed and maintained in alignment with their collective interests and practical needs. It lends significant weight and credibility to the standard.
  • Maintenance and Development by SIVI (the organisation): While the Pension Federation holds ownership, the day-to-day maintenance, ongoing development, and technical stewardship of the SIVI All Finance Standard (including its pension applications) are the responsibility of the SIVI organisation (Stichting SIVI – SIVI Foundation). SIVI is an independent, non-profit knowledge and standardisation institute dedicated to the financial services sector in the Netherlands, with a remit covering not only pensions but also insurance and absenteeism management. Its mission is to develop and manage standards that facilitate efficient digital business processes across the financial industry.

 

This governance model, separating industry ownership (ensuring relevance and buy-in) from neutral, expert maintenance (ensuring technical quality and adaptability), is crucial. Furthermore, the development of SIVI AFS is explicitly “demand-driven,” meaning its evolution is guided by requests for changes or expansions from the chain parties, third parties, and suppliers who use it. This ensures that the standard remains a living document, adaptable to the evolving needs of the financial services industry, rather than a static, one-off specification. This responsiveness fosters a sense of co-ownership and engagement from the industry, making it more likely that the standard will continue to solve real-world problems effectively.

4. The SIVI Advantage: Streamlining Operations and Enhancing Efficiency

The adoption of the SIVI standard offers tangible benefits to participants in the Dutch pension ecosystem, primarily by addressing long-standing inefficiencies associated with disparate data formats and bespoke communication protocols.

 

4.1. How SIVI “Makes Life Easier”

The core value proposition of SIVI in the pension data exchange context is its ability to simplify and standardise. By establishing a common data language, SIVI directly tackles several operational pain points:

  • Elimination of Custom Formats: Perhaps the most significant advantage is the elimination of the need for pension funds and asset managers to develop and maintain multiple custom data formats for each bilateral relationship. Historically, each pension fund might have its own preferred format for receiving investment data, and each asset manager might have its own format for providing it. This necessitated complex mapping exercises, custom interface development, and ongoing maintenance for each unique connection. SIVI replaces this fragmented landscape with a single, uniform structure. 
  • Reduced Manual Reconciliation: A direct consequence of standardised data formats is a reduction in the need for manual reconciliation. When data is received in a consistent and predefined structure, it can be more easily ingested and processed by automated systems, minimising the errors and discrepancies that often arise from manual data entry or manipulation during format conversion. This leads to improved data quality and reliability.
  • Consistent Data Delivery: SIVI ensures that “everyone uses the same tables and enters specific data in predefined fields”. This consistency is vital for accurate reporting, performance measurement, and risk oversight. It allows for more reliable comparisons and analyses, as data from different sources is structured in a comparable manner.
  • Benefits for Multi-Client Organisations: The advantages of standardisation are particularly pronounced for organisations that interact with numerous counterparties. For a large pension administrator working with multiple asset managers, or an asset manager serving many pension fund clients, the SIVI standard dramatically simplifies the data exchange landscape. Instead of managing a complex web of unique data feeds, they can implement a single, SIVI-compliant interface.

 

This chain of benefits from a uniform data structure to easier integration and reduced reconciliation stems directly from SIVI’s core function of eliminating the root cause of previous inefficiencies: non-standardised data exchanges. The value of this standardisation is amplified in the context of the Wtp reforms, which are increasing both the frequency and complexity of the data that needs to be exchanged.

 

4.2. Broader Operational Efficiencies

Beyond the direct benefits reported by early adopters, the SIVI All Finance Standard, in its broader conception, aims to deliver wider operational efficiencies across the financial services industry. These include:

  • Cost Reduction: A primary goal of SIVI AFS is to achieve “cost reduction related to interoperability through the use of open standards”. By minimising the need for bespoke solutions and custom development work, the standard helps to lower the overall cost of data exchange for the industry.
  • Reduced Testing and Configuration Efforts: Looking ahead, SIVI envisions the development of reference architectures for specific application areas. These could further reduce the effort needed for chain tests and minimise configuration activities for products, as common processes and data structures are pre-defined.

 

While efficiency and cost savings are primary drivers, the adoption of SIVI also offers less immediately obvious, yet strategically important, advantages. Standardised data inherently leads to more consistent and potentially higher-quality data, as definitions and structures are harmonised. This improved data quality, in turn, enables more reliable analytics, better-informed decision-making by pension fund trustees and executives, and more accurate performance reporting to participants and regulators. Furthermore, a standardised data framework makes it significantly easier for organisations to adapt their systems to new data requirements stemming from future regulatory changes or market developments, as the core “language” for data exchange is already established. For pension funds, the ability to ingest and compare asset manager data in a uniform format greatly facilitates robust oversight and more effective manager selection and monitoring processes.

5. SIVI’s Governance Framework: Ensuring Industry-Wide Trust and Utility

The effectiveness and widespread adoption of any industry standard heavily depend on a robust and trusted governance framework. The SIVI standard benefits from a clear structure that delineates ownership, maintenance responsibilities, and the process for its evolution, fostering confidence among its users.

 

5.1. Ownership by the Dutch Pension Federation (Pensioenfederatie)

A cornerstone of SIVI’s governance is that the standard, particularly in its application to the pension sector, is owned by the Dutch Pension Federation (Pensioenfederatie). The Pensioenfederatie is the principal advocacy group and representative body for nearly all pension funds in the Netherlands. Its membership collectively manages the vast majority of occupational pension assets in the country.

This ownership by a respected industry association, which directly represents the primary users (pension funds), is of paramount significance. It ensures that the standard is developed and maintained with the core interests and practical needs of these funds at the forefront. It also lends considerable credibility and authority to the standard, signalling that it is not an externally imposed requirement but rather an initiative driven by the industry for the industry. This model helps to build trust and encourages voluntary adoption, as pension funds can be confident that their perspectives are central to the standard’s design and purpose.

 

5.2. Maintenance and Development by SIVI (the organisation)

While the Pension Federation holds formal ownership, the crucial tasks of day-to-day maintenance, technical development, and ongoing stewardship of the SIVI All Finance Standard (AFS) fall to the SIVI organisation (Stichting SIVI). SIVI is an independent, non-profit foundation established as a knowledge and standardisation institute for the broader Dutch financial services sector. Its remit extends beyond pensions to include the insurance and absenteeism management industries. SIVI’s core mission is to develop, manage, and promote standards that facilitate efficient and effective digital business processes across these sectors.

This arrangement of industry ownership combined with maintenance by a dedicated, neutral standardisation body is a key strength. SIVI brings specialised technical expertise and a focus on standardisation best practices, ensuring the quality, coherence, and technological relevance of the AFS. The organisation acts as the custodian of the standard, managing its versions, documentation, and the tools that support its implementation, such as the AFD 2.0 Online data catalogue.

The fact that SIVI AFS development is “demand-driven” is also a critical aspect of its governance. This means that the standard is not static; it evolves over time based on requests for changes, enhancements, or expansions submitted by the various parties that use it, including pension funds, administrators, asset managers, and software suppliers. This iterative, user-centric approach ensures that the standard remains relevant to the practical, operational needs of the industry and can adapt to new regulatory requirements, market practices, or technological advancements. This direct line from user needs to standard evolution fosters a sense of shared ownership and continuous improvement.

 

5.3. Collaborative Approach to Standard Evolution

The governance model inherently promotes a collaborative approach to the SIVI standard’s evolution. By involving key industry players—such as insurers, intermediaries, service providers, and technology suppliers, in addition to pension sector participants—in the process of defining and refining the standard, SIVI ensures broad applicability and buy-in. SIVI aims for “joint governance with regard to functionality and cost development,” particularly when central platforms or large-scale systems leveraging the standard are considered.

This collaborative ethos is vital for the long-term sustainability and utility of the standard. It provides a framework for discussing proposed changes, resolving potential conflicts, and ensuring that the standard continues to meet the diverse needs of its user base. A clear governance model, involving both industry ownership and a dedicated, expert maintenance body, is crucial for any data standard to remain viable and trusted over time. It provides the necessary mechanisms for updates, version control, dispute resolution, and adaptation to future changes, such as clarifications or amendments to the Wtp or emerging technological opportunities. This structured yet responsive governance is a key factor in SIVI’s success within the Netherlands and its potential credibility as a model for similar initiatives elsewhere.

6. Beyond Dutch Borders: SIVI as a Blueprint for European Pension Data Harmonisation

The challenges and solutions emerging from the Dutch pension reforms, particularly the development of the SIVI standard, resonate well beyond the Netherlands. Many European Union member states are grappling with similar pressures on their pension systems, and the principles underpinning SIVI offer valuable insights for broader European data harmonisation efforts.

 

6.1. Common Challenges in European Pension Administration and Data Exchange

The European pension landscape is diverse, yet several common trends and challenges create a shared need for greater efficiency and standardisation in data exchange:

  • Shift from DB to DC Schemes: The transition from Defined Benefit to Defined Contribution schemes is not unique to the Netherlands. It is a widespread European trend, driven by factors such as increasing longevity, low interest rates, and the desire to make pension costs more predictable for employers. As notes, the Dutch reforms alone are expected to significantly increase the share of DC assets in the euro area from around 17% to 77%. This fundamental shift inherently increases data complexity, as DC schemes typically require more individualised tracking of contributions, investments, and outcomes.
  • Demographic Pressures: Ageing populations and the resultant “pension gap” are pressing concerns across the continent, demanding more sustainable, efficient, and transparent pension systems to ensure adequate retirement incomes.
  • Need for Enhanced Transparency and Member Information: Regulatory bodies like the European Insurance and Occupational Pensions Authority (EIOPA) consistently emphasise the need for better, clearer information for pension scheme members, alongside greater digitalisation and transparency regarding costs, charges, and investment performance. EIOPA has also advocated for pension tracking systems and dashboards at the Member State level.
  • Cross-Border Operations: While the IORP II Directive (Institutions for Occupational Retirement Provision) aims to facilitate a more integrated internal market for occupational pension funds, progress in cross-border pension operations has been limited. Diverse national social security and labour laws create complexities. The number of IORPs operating cross-border remains small and even saw a decline in 2023, indicating persistent barriers that streamlined data exchange could potentially help mitigate.
  • EU Data Strategy: Broader EU initiatives, such as the General Data Protection Regulation (GDPR) and the proposed Regulation on a Framework for Financial Data Access (FIDA), highlight the increasing importance of data access, portability, and security in the financial sector. FIDA, for instance, aims to establish standards for customer data access and portability across various financial products.
  • Feasibility of Data Collection: Industry bodies like PensionsEurope support efforts to improve transparency but stress that data collection requirements must be feasible, cost-effective, and respectful of the diversity of national pension systems and competences.

 

The Dutch Wtp reform, and the SIVI standard developed in response, can be seen as a national-level engagement with many of these broader European challenges. The pressures driving the need for SIVI in the Netherlands—individualisation, transparency, data complexity—are mirrored across the EU. Consequently, the success of SIVI in this context makes it a highly relevant case study for other European nations and EU bodies.

 

6.2. How SIVI’s Principles and Approach Could Address EU-Wide Needs

The SIVI standard, both in its technical design and its governance model, incorporates several features that could be beneficially applied to address EU-wide needs for pension data harmonisation:

  • Focused Scope on Operational Data: SIVI’s concentration on standardising the operational data exchange for investments and performance, while carefully excluding sensitive personal data and high-level strategic information, addresses a common requirement for efficiency and transparency in core administrative processes. This targeted approach could be more manageable to replicate than attempting an all-encompassing data standard.
  • Collaborative, Industry-Led Governance: The governance model, ownership by the Pension Federation and maintenance by the neutral SIVI organisation, offers a compelling template. Fostering similar national or regional industry-led initiatives, rather than relying solely on top-down EU mandates, might prove more effective in achieving practical data standardisation that respects local nuances while aiming for interoperability. This approach ensures buy-in from key national stakeholders and leverages local expertise.
  • Pragmatic and Adaptable Design: SIVI’s guiding principles, such as being “easily deployable” and giving “an eye for investments made”, align with the universal need for cost-effective and practical solutions that can be integrated into existing infrastructures without excessive disruption.
  • Balancing Transparency and Privacy: The clear definition of SIVI’s data scope, particularly its focus on aggregated cohort-level data for investment reporting, provides a working model for balancing the demand for increased transparency with the stringent data privacy requirements of GDPR, a critical consideration across the entire EU.

 

Beyond its technical specifications, it is SIVI’s development and governance process that offers a valuable non-technical blueprint for other European countries or EU bodies. This process, characterised by industry leadership, collaboration, and pragmatism, could inform strategies for tackling data harmonisation in a complex, multi-jurisdictional environment.

 

6.3. Alignment with Broader EU Data Strategies and Harmonisation Efforts

The principles embodied by SIVI resonate with several ongoing EU-level data strategies and harmonisation initiatives:

  • Financial Data Access (FIDA): The proposed FIDA Regulation aims to facilitate customer access to their financial data and enable data sharing with third-party providers across a range of financial products, including insurance-based investment products. While SIVI’s current focus is on inter-institutional exchange (administrator-to-asset manager), its foundational principles of standardised data definitions and secure access are philosophically aligned with FIDA’s objectives. Success with SIVI could inform how similar standards might be developed for other data-sharing scenarios envisaged under FIDA.
  • EIOPA’s Harmonisation Efforts: EIOPA is actively working towards “smarter, more harmonised” regulation and greater supervisory convergence across the EU. A key part of this involves ensuring that (re)insurers and pension funds have access to reliable and standardised data, particularly for areas like sustainability reporting and risk management. EIOPA’s review of the IORP II Directive also includes calls for more effective use of data and enhanced transparency for pension scheme members. Successful national standards like SIVI can provide practical examples of how such standardisation can be achieved.
  • Data Portability: The EU places a strong emphasis on the right to data portability, allowing individuals to move their data between service providers. Standards like SIVI, by making data more structured and machine-readable, inherently enhance its portability between compliant systems, even if the initial application is not directly consumer-facing.
  • Learning from a Major Market: The Dutch pension system is one of the largest and most sophisticated in the EU. Consequently, successful innovations and standardisation initiatives originating from the Netherlands, such as SIVI, are likely to be observed with considerable interest by regulators and industry bodies in other EU countries and at the EU level.

 

SIVI’s focus on a specific, critical segment of data exchange (administrator-asset manager interactions for aggregated investment and performance data) suggests that successful European harmonisation might be more achievable through a series of targeted, domain-specific standards rather than attempting to create a single, monolithic EU pension data standard from the outset. This approach aligns with EIOPA’s push for “smarter, more harmonised” regulation that can be targeted and proportionate. Such an approach could involve identifying common, high-impact data exchange areas across Member States and encouraging the development of interoperable, SIVI-like standards for these specific domains, which could then potentially be linked or aggregated over time to build a more cohesive European pension data landscape.

7. Navigating the Future: Embracing Standardised Pension Data for a Resilient European Pension Ecosystem

The journey of the Dutch pension system through the Wtp reforms, and the concurrent emergence of the SIVI standard, offers critical lessons for the broader European pension landscape. Data standardisation is no longer a niche technical concern but a strategic imperative for building efficient, transparent, and resilient pension systems capable of meeting the challenges of the 21st century.

 

7.1. The Strategic Imperative of Data Standardisation

The case of SIVI clearly demonstrates that data standardisation is fundamental for:

  • Operational Efficiency: Reducing the operational burden on pension fund administrators and asset managers by eliminating bespoke data formats and manual processes. This translates into cost savings and faster processing times.
  • Data Quality and Reliability: Ensuring consistent and accurate data for member administration, investment oversight, performance reporting, and regulatory compliance.
  • Enhanced Risk Management: Providing a clearer, more standardised view of investment exposures and performance, which is crucial for effective risk management by pension funds.
  • Facilitating Regulatory Compliance: Streamlining the ability to meet the complex data reporting requirements associated with reforms like the Wtp and other evolving European regulations.
  • Improving Member Engagement and Outcomes: While SIVI focuses on inter-institutional exchange of aggregated data, the efficiencies and data quality it promotes can indirectly support better member communication and more informed decision-making, ultimately contributing to better pension outcomes.

 

For pension fund administrators, standardisation means a reduced operational burden, improved data quality for crucial tasks like member record-keeping and benefit calculations, and more streamlined reporting to stakeholders. For asset managers, it translates to simplified client reporting processes, easier onboarding of pension fund clients who adopt the standard, and a reduction in the resources needed to support multiple proprietary data formats. For compliance officers, standardised data exchange enhances the ability to monitor adherence to protocols, ensure data integrity, and demonstrate compliance with increasingly stringent regulatory requirements across Europe.

The Wtp and the SIVI standard highlight the growing importance of data not just for routine operational processing but as a strategic asset within the pension industry. Effective data management and exchange, underpinned by robust standards, will be key to navigating future reforms, managing complex risks, and ultimately enhancing the value delivered to pension scheme members.

 

7.2. Preparing for a Standardised Future: Recommendations for Stakeholders

The trend towards greater data standardisation in pensions is clear. Stakeholders across Europe should consider proactive steps:

  • Pension Funds and Administrators:
    • Assess Current Processes: Undertake a thorough review of existing data exchange processes with asset managers and other third parties to identify current pain points, inefficiencies, and areas where standardisation could deliver significant benefits.
    • Engage with Industry Bodies: Actively participate in discussions and initiatives led by national pension associations, PensionsEurope, and other relevant industry bodies concerning data standardisation.
    • Invest in Flexible IT: Prioritise investments in modern, flexible IT infrastructure that can readily adapt to standardised data formats and communication protocols. Legacy systems may require significant upgrades or replacement to leverage the full benefits of standardisation.
  • Asset Managers:
    • Develop Standardised Reporting Capabilities: Invest in systems and processes to support standardised data reporting protocols like SIVI. This may involve adapting existing reporting platforms or developing new capabilities.
    • Proactive Client Communication: Engage proactively with pension fund clients to understand their evolving data requirements and communicate readiness to support emerging industry standards. Early alignment can be a competitive advantage.
  • Regulators and Industry Bodies (across Europe):
    • Study Successful Models: Examine successful national standardisation initiatives, such as SIVI in the Netherlands, to understand their development processes, governance structures, and impact.
    • Foster Collaboration: Encourage and facilitate collaboration between national pension sectors, technology providers, and regulatory authorities to identify common data exchange needs and potential areas for harmonisation. This should respect national specificities, as emphasised by PensionsEurope.
    • Support Practical Standards: Promote the development of practical, industry-driven standards that are technically sound, cost-effective to implement, and meet the genuine needs of the pension ecosystem.

 

The key message for all stakeholders is that data standardisation is not a passive development to be observed from the sidelines, but an active and evolving trend that requires engagement. Proactive assessment of internal capabilities, strategic planning for adoption, and participation in broader industry discussions are crucial for navigating this transition successfully. Early adoption of, or alignment with, robust data standards can become a significant competitive differentiator, signalling operational efficiency, technological maturity, and a forward-thinking approach to pension administration and asset management.

 

7.3. AssetIdBridge: Your Partner in Navigating Pension Data Harmonisation

The journey towards harmonised pension data, as exemplified by the SIVI standard in the Netherlands, presents both challenges and opportunities. Understanding the intricacies of these emerging standards, their technical underpinnings, and their strategic implications is crucial for all participants in the pension ecosystem. AssetIdBridge, one of our partner platforms, with its expertise in financial data management and standards harmonisation, is positioned as a thought leader and a valuable partner for organisations seeking to navigate this evolving landscape. 

The insights gleaned from the Dutch experience with SIVI can inform strategies for modernising pension administration, enhancing data exchange efficiency, and ensuring regulatory compliance not only in the Netherlands but across Europe. As professionals search for solutions related to “pension data standard Netherlands” or “pension fund data reporting,” understanding the principles and successes of SIVI will be paramount, and guidance on implementing such standards or the tools to comply with them will be increasingly sought after.

AssetIDBridge gives pension ecosystem participants the tools to harmonise their asset identifiers.

Conclusion

The Dutch Wet toekomst pensioenen has set in motion a fundamental transformation of one of Europe’s largest pension systems, with the transition to individualised Defined Contribution schemes creating an urgent need for more sophisticated and voluminous data exchange. The SIVI All Finance Standard, born out of proactive industry collaboration led by the Pension Federation, stands as a critical enabler of this transition. By establishing a uniform language for investment and performance data, specifically at an aggregated cohort level to protect personal information, SIVI offers a pathway to significant operational efficiencies, reduced manual effort, and improved data quality, as evidenced by early adopters.

The governance of SIVI, characterised by industry ownership and expert maintenance, fosters trust and ensures that the standard evolves in line with the practical needs of its users. This pragmatic and collaborative approach, coupled with a clear and privacy-conscious data scope, provides valuable lessons that extend far beyond the Netherlands.

As other European countries face similar pressures from pension reforms, demographic shifts, and the overarching EU drive for financial data harmonisation (evidenced by initiatives like FIDA and EIOPA’s work), the SIVI model offers a compelling case study. It demonstrates that industry-led, domain-specific standardisation can provide tangible benefits and serve as a building block for a more integrated and efficient European pension data ecosystem. The strategic imperative for pension fund administrators, asset managers, and compliance officers is to recognise data standardisation not merely as a technical adjustment but as a fundamental component of future-ready pension operations. Proactive engagement with these evolving standards will be key to navigating the complexities of modern pension administration and harnessing the power of data for a more resilient and transparent retirement future across Europe.

References

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