The Future Pensions Act (Wtp) and the resulting changes to our pension scheme represent the most significant and complex reform ever submitted to the Accountability Body (AB) or its predecessors for advice. Under the new legislation, participants no longer have an individual right to object to the transfer of their accrued pension entitlements into the new scheme. Instead, the AB has been assigned an enhanced advisory role in this process. This has reinforced the AB’s sense of responsibility towards all SSPF participants. In light of this, the AB considers it important—departing from its usual practice of advising the SSPF board—to inform all participants about how this advice was formulated.

Nationally, the Future Pensions Act has sparked years of debate, both within the Dutch ‘polder’ and among various groups of SSPF participants, and it was recently the subject of political discussion. Throughout this lengthy preparatory phase (since 2022), the AB has been kept informed by the SSPF board and the Shell Pension Bureau (SPN) about the development and scope of the legislation, including through several knowledge sessions. The AB also engaged external experts for advice to ensure a thorough understanding. In May 2025, the AB was informed about the financial implications of the proposed transition decision. On 28 May, the AB received the draft request for advice and on 5 June 2025, the SSPF board formally adopted the transition decision - unchanged from the draft version.

Advice to the SSPF board
Between early May and 6 July, the AB thoroughly reviewed the request for advice and the extensive supporting documentation. The findings were discussed weekly, with numerous follow-up questions submitted to SPN, all of which were answered. In addition, 2 full-day plenary sessions were held to complete the assessment and to reach a final decision. Throughout this process, the AB was supported by a highly regarded consultant from ORTEC, a well-respected advisory firm in this field.

The AB has decided to issue a positive recommendation regarding the SSPF board’s proposed transition decision. The main consideration was that, in the vast majority of possible economic scenarios, the new Flexible Contribution Scheme (FCS) delivers better pension outcomes for all participants compared to the current scheme under the same economic conditions. The AB also took into account that (significant) fluctuations in pension payments will be mitigated by spreading investment returns over 5 years, that the reserve for pension beneficiaries will make the likelihood of pension reductions in the first 15 years of the FCS very low and that active participants who are negatively affected by the shift to a fixed contribution scheme will receive financial compensation. However, the AB has made 3 recommendations which, in its view, would further strengthen the transition to the new scheme and enhance its overall robustness.

Assessment of the new pension scheme
The decision to transition is based on the Transition Plan as agreed upon by Shell Netherlands and the Central Works Council. Within the framework of this plan, the SSPF board developed the structure of the new scheme, assessing it for both feasibility and overall balance. The advisory right of the AB is also limited to assessing whether the structure of the new scheme, which is designed based on the Transition Plan, is balanced or not. In other words, an Accountability Body cannot issue negative advice simply because it prefers a different scheme. It may only give negative advice if the decision to transition results in a disproportionate disadvantage for active participants (current employees), deferred participants (former Shell employees who have not yet started receiving an SSPF pension) or pension beneficiaries.

The AB concluded that the way the SSPF board has shaped the new scheme based on the Transition Plan is not expected to result in any imbalance for active participants, deferred participants or pension beneficiaries. This conclusion is based on the following findings:

• The Flexible Contribution scheme is considered the best fit for the characteristics of the SSPF population, partly because there is already experience with this type of scheme at the other Shell fund, Shell Nederland Pensioenfonds Stichting (SNPS).
• The distribution of 'the buffer', based on the entitlements accrued as of 1 January 2027, ensures that the rights under the current contract are respected as much as possible, and that any intergenerational shift in pension assets is minimised.
• That after a deliberate and very limited redistribution of assets, the condition is met that each age group of participants will see an improvement in their pension outlook — up to life expectancy — in at least two-thirds of the economic scenarios prescribed by De Nederlandsche Bank, compared to the current scheme;
• This supports the realisation of one of the objectives of the Future Pensions Act, namely the prospect of a pension that retains its purchasing power.
• The allocation of a reserve for pension beneficiaries, valued at EUR 500 million and intended to remain in place until at least 2042 (a period of 15 years), is expected to reduce the probability of a decrease in the initially enhanced pension benefit to below 5% on average over that timeframe. The reserve is also designated for active and deferred participants who retire after the transition, for the years in which the reserve has not yet been fully deployed.
• That investment returns during the benefit phase are averaged over 5 consecutive years, so that a poor return in any given year has only a limited direct impact on the pension benefit.
• That the funding of the uniform contribution compensation is provided from the fund’s assets, given that the above objectives can be achieved.
• That, based on the results of the Risk Preference Survey (RPO) conducted among participants, 3 options (so-called life cycles) will be made available for active and deferred participants, enabling these groups to influence their pension ambition and the level of risk they wish to take, in line with the spirit of the Future Pensions Act.
• In part due to the contributions of the Voeks (the association of former Shell employees) Hearing Rights Committee (VHC) and the board, a sound valuation of the sponsor guarantee has been achieved. However, under the new pension arrangement, the sponsor guarantee can no longer be retained.
• Clear agreements have been laid down in an emergency protocol regarding a minimum funding ratio of 125% in the third quarter of 2026 as a condition for transition. This minimum funding threshold has been set in part to ensure a sufficient level of certainty that the objectives of a balanced transition can be achieved.

Additionally, within the framework of the Transition Plan of Shell Netherlands and the Central Works Council, the board has been requested to consider the following points:

• The possibility of offering a second, more offensive Collective Variable Pension (CVP) for pension beneficiaries was considered. However, the findings of the current Risk Preference Survey (RPO) indicate limited demand for such an option, as SSPF participants demonstrated a relatively risk-averse profile. In addition, the pension administrator, Achmea Pension Services (APS), is not in a position to implement a second CVP, and this product is currently not available in the broader pension market. The AB acknowledges that, under these circumstances, the board is unable to offer this option at present. To ensure future alignment with participant preferences, the AB has recommended repeating the RPO in 2027 to reassess pension beneficiaries’ risk appetite and evaluate the potential need for a more offensive CVP. The board has confirmed that a new RPO is scheduled for the second half of 2027.
• To offer a risk-free fixed benefit to current and future pension beneficiaries. The AB understands that this cannot be provided by the fund itself (as this is not permitted by law). Such a fixed benefit can therefore only be arranged through an external insurer. The AB appreciates SSPF’s decision to facilitate a solution for this with one or more external insurers, based on attractive (collective) terms for SSPF participants. Of course, participants are free to arrange a fixed benefit with an insurer of their own choosing.
• To establish a reserve for pension beneficiaries of EUR 500 million to EUR 750 million. The AB understands that a reserve of EUR 500 million was chosen because a higher reserve would not provide significantly more protection and, over time, would lead to a shift of (remaining) assets between generations (from old to young).

Recommendations AB
In addition to the previously mentioned recommendation to conduct a new RPO in 2027, the AB has included two further recommendations in its advice.

The first point concerns the financial position of older pension beneficiaries. The allocation of the fund’s assets across participants is determined by the value of their pension entitlements—that is, the projected pension benefits. Within this framework, it is observed that all participants are expected to receive a more favourable pension outcome in at least two-thirds of the prescribed economic scenarios when compared to the current scheme.

For active participants who are yet to retire, the capital required to secure their pension outcome is, quite understandably, higher than that needed to fund payments for older pension beneficiaries, whose remaining pension period is considerably shorter. Additionally, the capital held by active participants and younger pension beneficiaries benefit from a longer investment horizon, enabling it to generate returns over a more extended timeframe. This is not the case for older pension beneficiaries, whose investment horizon is much shorter.

Consequently, the pension capital of active participants increases to such a degree that, under the median of all economic scenarios, they can expect a pension outcome which can be approximately 20% larger. However, in extremely adverse economic conditions, their pension outcome would be lower than what would have been achieved under the existing scheme.

For participants aged 85, the average life expectancy is still over 6 years, while for those aged 90, it is less than 4 years. The pension increase they will receive at the time of the transition in 2027 is sufficient to cover inflation throughout their remaining life expectancy in two-thirds of the economic scenarios. However, due to this relatively short remaining period, the pension increase for these participants is also relatively modest. As a result, in the event of higher inflation shortly after the transition, a loss of purchasing power may occur sooner. In addition, a considerable number of these participants are likely to outlive the average life expectancy, which increases the risk that purchasing power will decline over time. This is not the case under the current scheme, where (conditional) indexation is not linked to the life expectancy of pensioners.

Under the new scheme, the requirement set out in the Transition Plan — that a better pension outcome must be achieved in two-thirds of the economic scenarios — is also met for older pension beneficiaries. Based on this, the AB considers the board’s decision to proceed with the transition to be balanced and well-founded. That said, as the likelihood of not meeting this criterion is greatest for older pension beneficiaries, the AB has recommended mitigating this risk to bring it more in line with that faced by younger pension beneficiaries and, by extension, with that of active participants, for whom the risk is considerably lower. One way to achieve this would be through a limited, additional redistribution of assets. This would allow for a further increase in the pension adjustment for this group in 2027. Crucially, such a redistribution would not compromise the two-thirds criterion set out in the Transition Plan. While the new scheme meets the two-thirds criterion even for older pension beneficiaries, this group is still at relatively higher risk. The AB recommends reducing this gap by slightly increasing their 2027 pension adjustment through a modest redistribution—without violating the two-thirds requirement for other groups.

This would align with the SSPF board’s own fairness framework, which specifically highlights the shorter investment horizon of older pensioners. Unfortunately, the board has chosen not to act on this recommendation.

The other recommendation concerns closely monitoring the capacity of the pension administrator, Achmea Pension Services (APS), to implement the scheme properly and on time. The AB has growing concerns due to further delays in ASP’s preparations, as recently evidenced by the postponement of the intended transition date for two other APS clients and the recently announced end of Achmea Pension Services’ operations in 2030.

Note: The above report from the Accountability Body (AB) is a concise summary of the main points from the transition decision and the AB’s key findings on the matter. To ensure accessibility for a broad audience, (legal) jargon has been avoided as much as possible. For details of the implementation plan, please refer to the website: www.shellpensioen.nl.