The Law of 18 December 2015: three changes, three tests
Variable guaranteed return (WAP Art. 24)
The fixed 3.25%/3.75% guarantees were replaced by a variable rate: 85% of the 24-month average 10-year OLO yield, rounded to 25 basis points, floor 1.75%, cap 3.75%. The rate held at 1.75% from 2016 through 2024 and rose to 2.50% on 1 January 2025, its first move in nine years.
Our test: is the insurer crediting 2.50% on the correct contribution generations under the plan's method (vertical: all reserves; horizontal: new contributions only)? The Conformity Audit module demonstrates exactly this check.
Sources: Vanbreda · AKDRetirement-age alignment
Statutory retirement age rose to 66 in 2025 and reaches 67 on 1 January 2030; the 2015 Act aligned supplementary-plan retirement ages with the statutory age and restricted early liquidation. Early retirement requires 44 years of career at 60, 43 at 61, or 42 at 63.
Our test: do the plan rules, the insurer contract, and member communications reflect the cohort schedule? The valuation models retirement cohort-by-cohort, and the Valuation Lab quantifies the 66-to-67 shift (about -4% of obligation on the demo plan).
Sources: AKD · etuiDeath cover for deferred members
Members who leave employment but keep reserves in the plan ("sleepers") must be offered the option of continued death coverage, so their beneficiaries are not left uncovered by an unelected default.
Our test: were post-2016 leavers offered the election, is the elected coverage priced and reserved correctly, and does the valuation carry the right liability for each election? The demo census carries the election flag on every deferred record for exactly this purpose.
Analyzed against plan exit files and insurer confirmations at awardThe wider compliance frame (Task i)
| Requirement | What Belgian law requires | What we verify |
|---|---|---|
| Vesting (WAP) | Acquired reserves vest after one year of affiliation; reserves are the member's on exit. | Plan rules and insurer statements honor acquired-reserve rules; vested vs non-vested split disclosed in the IAS 19 figures as the RFQ requires. |
| DB2P / Sigedis reporting | Second-pillar plans report annually to the national DB2P database. | Filings exist, are current, and reconcile to the insurer's reserve statements. |
| FSMA supervision | Occupational plans and their insurers fall under FSMA conduct supervision; sectoral funding reporting applies. | Any FSMA correspondence reviewed; plan features tested against current FSMA guidance. |
| Sex-neutral treatment | EU and Belgian rules constrain sex-based differentiation in occupational benefits. | Benefit formula and tariffs reviewed; mortality reported by gender for analysis while benefit treatment stays compliant. |
| Wage indexation interface | Automatic indexation (health index) drives pensionable salary; 2026-27 "cent index" bracket measures alter pass-through. | Pensionable-salary definition tested against LCP practice and current indexation law; salary assumption set accordingly. |
| Anticipated changes (Task j) | Live reform stream: 2025 pension package (bonus-malus, early-retirement phase-outs), indexation bracket measures, next pivot crossings forecast Jan and Dec 2027. | The report's forward-looking section inventories pending changes with quantified plan impact where measurable. |