European Market Infrastructure Regulation 3 (EMIR 3) is the most recent major reform to EMIR. Here’s what it means for the 2025 economy in the Netherlands, especially for pensioners.
Dutch Economy at a Glance
The economy of the Netherlands is mixed and highly developed. De Nederlandsche Bank (DNB) is the country’s central bank, overseeing its economic policy.
Gross Domestic Product
Nominal GDP per capita, 2025: $70,480
Nominal GDP ranking per capita, 2025: 10th
Purchasing power parity (PPP)-adjusted GDP per capita, 2025: $84,570
PPP-adjusted GDP ranking per capita, 2025: 10th
GDP growth rate, 2025: 1.4%
Data from the International Monetary Fund.
Trading Partners & Memberships
Dutch import trading partners: Germany, United States, China, Belgium, United Kingdom, France
Dutch export trading partners: Germany, Belgium, France, Italy, United Kingdom, United States
Dutch memberships & Forums: OECD, European Union (EU), WTO
Unemployment Rates
National, June 2025: 3.8%
Data from the Centraal Bureau voor de Statistiek (CBS).
2025 Dutch Economic Developments & Trends
Wage growth and increased disposable income
Declining interest rates and falling inflation rates
Low consumer confidence
Housing market shortages
U.S. tariffs on Dutch products
Increased government spending in healthcare and social security, business investment, defense
Increased budget deficit
Global trade tensions and geopolitical uncertainty
EMIR 3 impacts pensions
Pension System
The Dutch pension system is multi-faceted, composed of a state pension system, private employee pension system, and individual private pensions. Most Dutch pension funds use EUR interest rate swaps (IRS), providing some protection against volatile interest rates, even during times of economic uncertainty.
EMIR 3: Impacts & Economic Outlook
EMIR 3 introduced two new major requirements, the Active Account Requirement (AAR) and the Representativeness Obligation (RO). Both impact the DV01 (Dollar Value of a Basis Point) and majority of the assets in the Dutch pension sector.
Pension funds will likely take one of two primary routes in response to EMIR 3:
- Moving parts of the swap portfolios to EUREX.
- Complying with RO via “box ticking” strategies.
Learn More
Our experts further discuss the impact of EMIR 3 and the Dutch pension reforms on pension fund behavior going forward.
Disclaimer
Non Independent Research
This document is issued by Coöperatieve Rabobank U.A. incorporated in the Netherlands, trading as “Rabobank” (“Rabobank”) a cooperative with excluded liability. The liability of its members is limited. Authorised by De Nederlandsche Bank in the Netherlands and regulated by the Authoriteit Financiële Markten. Rabobank London Branch (RL) is authorised by De Nederlandsche Bank, the Netherlands and the Prudential Regulation Authority, and subject to regulation by the Financial Conduct Authority and limited regulation by the Prudential Regulation Authority. Further details are available on request. RL is registered in England and Wales under Company no. FC 11780 and under Branch No. BR002630. This document is directed exclusively to Eligible Counterparties and Professional Clients. It is not directed at Retail Clients.
This document does not purport to be impartial research and has not been prepared in accordance with legal requirements designed to promote the independence of Investment Research and is not subject to any prohibition on dealing ahead of the dissemination of Investment Research. This document does NOT purport to be an impartial assessment of the value or prospects of its subject matter and it must not be relied upon by any recipient as an impartial assessment of the value or prospects of its subject matter. No reliance may be placed by a recipient on any representations or statements made outside this document (oral or written) by any person which state or imply (or may be reasonably viewed as stating or implying) any such impartiality.
This document is for information purposes only and is not, and should not be construed as, an offer or a commitment by RL or any of its affiliates to enter into a transaction. This document does not constitute investment advice and nor is any information provided intended to offer sufficient information such that is should be relied upon for the purposes of making a decision in relation to whether to acquire any financial products. The information and opinions contained in this document have been compiled or arrived at from sources believed to be reliable, but no representation or warranty, express or implied, is made as to their accuracy, completeness or correctness.
The information contained in this document is not to be relied upon by the recipient as authoritative or taken in substitution for the exercise of judgement by any recipient. Any opinions, forecasts or estimates herein constitute a judgement of RL as at the date of this document, and there can be no assurance that future results or events will be consistent with any such opinions, forecasts or estimates. All opinions expressed in this document are subject to change without notice.
To the extent permitted by law, neither RL, nor other legal entities in the group to which it belongs accept any liability whatsoever for any direct or consequential loss howsoever arising from any use of this document or its contents or otherwise arising in connection therewith.
Insofar as permitted by applicable laws and regulations, RL or other legal entities in the group to which it belongs, their directors, officers and/or employees may have had or have a long or short position or act as a market maker and may have traded or acted as principal in the securities described within this document (or related investments) or may otherwise have conflicting interests. This may include hedging transactions carried out by RL or other legal entities in the group, and such hedging transactions may affect the value and/or liquidity of the securities described in this document. Further it may have or have had a relationship with or may provide or have provided corporate finance or other services to companies whose securities (or related investments) are described in this document. Further, internal and external publications may have been issued prior to this publication where strategies may conflict according to market conditions at the time of each publication.
This document may not be reproduced, distributed or published, in whole or in part, for any purpose, except with the prior written consent of RL. By accepting this document you agree to be bound by the foregoing restrictions. The distribution of this document in other jurisdictions may be restricted by law and recipients of this document should inform themselves about, and observe any such restrictions.
A summary of the methodology can be found on our website
© Rabobank London, 60 London Wall, London, EC2M 5AA +44(0) 207 809 3000