The Belgian government has been compiling data regarding Belgian second pillar pension plans in a database.  This database, referred to as DB2P and managed by Sigedis, will be used to help ensure compliance with Belgian tax, social and pension law.  It is also designed to be a source of information for the employees.

In most cases, the obligation to upload the pension plan information falls with the insurance companies and other pension vehicles.  There is one notable exception.  In case the employer has a pension promise for one or more employees which is internally funded (e.g. by making balance sheet provisions), the related information needs to be provided by the employer from 1 January 2012.  The duty to inform the government consists of a one-off declaration of the existence of this type of pension arrangement and an annual update of the pension account (the accrued reserves).
Given this additional administrative obligation, you could opt to “externalise” this type of pension promises to a third party before the end of 2011.  PwC will be glad to provide advice in this regard.