Stichting Pensioenfonds Cosun (PF Cosun) has published its “Implementatieplan Versie 2.0” on September 16, 2025, outlining its strategy for adapting to the Wet toekomst pensioenen (Wtp) and transitioning to a Solidaire Premieregeling (SPR).
Projected Operational Readiness for Solidaire Premieregeling
PF Cosun anticipates that its pension administrator, Appel Pensioenuitvoering, along with asset managers Van Lanschot Kempen IM, BlackRock, and State Street, will be operationally ready to implement the new Solidaire Premieregeling (SPR) by January 1, 2026. This readiness includes adjustments to systems, processes, and staffing. The fund’s project group monitors the progress of these external parties. (Implementatieplan Versie 2.0, p. 6, 11, 20)
Enhanced Data Exchange and System Integration for Asset Management
The implementation of the new pension system necessitates a direct communication flow between pension administration and the asset management chain. PF Cosun plans to establish a “target operating model” (TOM) in collaboration with Appel, Van Lanschot Kempen IM, BlackRock, and State Street. This model will define processes, tasks, and responsibilities, including fall-back procedures for information flows. The accounting at State Street will transition from a monthly to a daily frequency by 2025 to facilitate timely data exchange. The strategic norm portfolio and interest rate hedging will be adjusted monthly based on the age structure and asset distribution of the participant population. (Implementatieplan Versie 2.0, p. 44)
Strategic Adjustments to Investment Portfolio Post-Transition
PF Cosun intends to convert its investment portfolio to align with the strategic investment portfolio of the new pension scheme after the transition date, specifically in January 2026. The fund explicitly avoids adjusting the portfolio before the transition date to mitigate increased risks to achieving transition goals. To manage interest rate risk, the fund will adjust its curve position before the transition moment to minimize the volume of interest rate sensitivity to be traded on less liquid maturities. The fund also began partially reducing its allocation to NL Mortgage Loans in early 2025, with the expectation that the full desired reduction may not be completed by the transition date. The asset class “corporate bonds” will be used to bridge the gap between the desired and actual allocation in NL Mortgage Loans. (Implementatieplan Versie 2.0, p. 56)
Proactive Risk Mitigation for Invaardekkingsgraad
To manage short-term risks until the transition date, PF Cosun has implemented measures to protect the invaardekkingsgraad (transfer coverage ratio). A trigger threshold of 118% has been defined. If the actual coverage ratio reaches this threshold, the fund will reduce interest rate risk by increasing interest rate hedging to 100% (from the current 75%). Depending on the cause of reaching the trigger, equity risk may also be reduced through non-linear investment products (put options) or by lowering equity allocation. In February 2025, the fund increased interest rate hedging to 100%, currency hedging on business assets to 100% (from 50%), and implemented a put option on MSCI to hedge equity risk. (Implementatieplan Versie 2.0, p. 55)
Anticipated Increase in Transaction Costs for 2026
Due to the adjustment of the strategic investment portfolio, transactions will be executed around the transition moment (or in the first month after transition), leading to a one-time increase in transaction costs in 2026. While the fund aims to limit a structural increase in transaction costs by setting bandwidths around the normal allocation of investment categories, the dependence of the norm portfolio on portfolio and return developments may lead to more frequent transactions compared to the current investment portfolio setup. (Implementatieplan Versie 2.0, p. 45)
New Service Level Agreements with External Managers
PF Cosun plans to establish new service agreements and/or SLA agreements with its outsourced parties. This includes Van Lanschot Kempen IM, BlackRock, and State Street. These agreements are expected to be finalized in a timely manner to ensure clarity on costs and responsibilities. (Implementatieplan Versie 2.0, p. 15, 51)
Increased Costs for Asset Management Services
The fund anticipates additional costs for the services of the Fiduciary asset manager and an increased frequency of accounting activities at State Street. The latter are estimated at €36,000 per year, effective January 1, 2025, and are categorized under asset management costs. The impact of this expected cost increase on total asset management costs (as a percentage of average assets) is considered very limited. (Implementatieplan Versie 2.0, p. 45)
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