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.
Scope. This guarantee is a defined contribution control. In a defined benefit plan it reaches the personal contributions rather than the plan as a whole. The test that governs a Belgian DB plan’s solvency is the minimum financing requirement, set out below. The Performance Work Statement raises the guarantee expressly at Task (j), so both are in scope, and we keep them apart.
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 test that governs solvency: minimum financing
The minimum financing requirement (MFC)
For a Belgian defined benefit plan, solvency is tested by determining each member’s vested rights at the calculation date, most often a pro rata of the lump sum, and discounting them at 6 per cent using the MR/FR mortality tables. This is the test, not the minimum return on contributions.
What experience says will be found here. Where a plan is financed through a group insurance on the individual level annual premium method, the requirement is almost always covered, because the discount rate inside insurer premiums sits well below the legal 6 per cent. The exception is above age 55, where deficits of mathematical reserve against the minimum financing figure do appear. Belgian law requires any such deficit to be financed collectively, through the financing fund attached to the group insurance.
Our test: we compute the minimum financing figure member by member, compare it against the reserve actually held, and report every deficit with the collective financing that should have covered it. Larger Belgian insurers run this control systematically. Whether it is run on this plan is a question we put to the insurer on day one, and it is the first thing we would want answered.
What it requires: the règlement d’assurance de groupe in full, meaning the general conditions, the particular conditions carrying the lump sum and premium definitions, the financing agreement, the insurance convention, and every addendum accumulated over the life of the contract.
Authority: WAP article 19, with the Royal Decree of 14 November 2003 article 48 §2, which sets the technical basis at 6 per cent on the MR/FR tables. Confirmed by our certifying actuary, a member of the Institute of Actuaries in Belgium.The wider compliance frame (Task i)
| Requirement | What Belgian law requires | What we verify |
|---|---|---|
| Minimum financing | A DB plan must hold reserves at least equal to the vested rights discounted at 6% on MR/FR. Deficits must be financed collectively through the financing fund. | Computed member by member and compared against the reserve held; deficits reported by age band, with particular attention above age 55, together with the collective financing applied. |
| 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. |