FSMA Launches Updated Cost Comparison Tool for Second and Third Pillar Pension Products

Key Takeaways

• The Belgian Financial Services and Markets Authority (FSMA) released a new version of its consumer-facing tool for comparing the costs of supplementary pension products.
• The tool benchmarks a product's costs against the average for similar products, which increases fee transparency and the likelihood that outliers will draw scrutiny.
• Compliance teams at pension product providers and distributors should review their cost disclosures and pricing against these benchmarks.

Deep Dive

The Belgian Financial Services and Markets Authority (FSMA) released a new version of its consumer-facing tool for comparing the costs of supplementary pension products. The tool benchmarks a product's costs against the average for similar products, which increases fee transparency and the likelihood that outliers will draw scrutiny. Compliance teams at pension product providers and distributors should review their cost disclosures and pricing against these benchmarks.

For compliance teams, the main significance is indirect. Consumers will have easier access to standardized benchmarking, which increases pressure on providers whose fees exceed peer averages. It also gives the regulator a visible reference point for assessing value for money and fee transparency. Although the release does not describe supervisory consequences, firms with above-average costs should be prepared for more consumer inquiries, complaints, and possible supervisory questions about cost justification.

The release gives no effective date beyond the launch on September 15, 2026, and sets no deadline for firms. It also does not describe the methodology, data sources, product scope, or whether providers must submit or validate data. These details are important because inaccurate or outdated data in the tool could create reputational and conduct risks. The release is available only in French and Dutch, so teams should review the source material in those languages, and should not rely on this summary alone, before finalizing any response.

Recommended actions include:
- Review the new tool and locate how each of the firm's products is represented.
- Verify that cost data submitted or reported to the FSMA is accurate and current.
- Benchmark product fees against the tool's averages and document the rationale for any material deviations.
- Confirm that marketing materials, KIDs/pension disclosures, and sales processes are consistent with the tool's outputs.
- Brief customer-facing and complaints-handling teams.
- Monitor FSMA communications for future updates to the tool.

Overall impact is low to moderate. There is no direct compliance burden, but the update strengthens transparency expectations in the Belgian pension market and raises conduct risk for firms with high-cost products.

Source: Financial Services and Markets Authority