The report “When the pension crosses borders” was launched and debated during the Nordic Council Freedom of Movement Group’s meeting in Oslo on 16 April. This was held as part of the 2026 Nordic Council Theme Session.
Read this article in Norwegian on Arbeidsliv i Norden
Vibeke Hammer Madsen was on the panel debating the report’s findings and her message to politicians was strong and clear:
“Ministers must now take responsibility for solving the three biggest border barriers: taxation, pension and Nordic e-ID. If they manage to solve these three, there will be hardly any border barriers left in the Nordic region,” Hammer Madsen said.
Thinks more will work in several Nordic countries
There is no joint Nordic overview over how many citizens have pension rights across borders in the Nordic countries.
Yet mobility between the Nordic countries has never been greater. According to Nordic Labour Mobility 2023, Eurostat and the OECD, between 1.1 and 1.2 million Nordic citizens have worked or lived in at least one other Nordic country during their working lives.
This number is expected to rise in the coming years.
Citizens with work connections in a different Nordic country
Two become one single pension
From the citizens’ perspective, a pension is seen as one single, unified journey where public pensions and labour market pensions together provide financial security in old age.
From the systems’ perspective, however, a pension is divided into two independent pillars that are not designed to work together. The analysis shows it is precisely in the transitions between these two pillars that problems occur.
A lack of access to information and traceability as well as different administrative processes are all amplified when a citizen has pension rights in several countries.
This means that citizens often only gain an overview late in life – often shortly before retirement – when opportunities to fix mistakes are limited.
The Nordic pension paradox
The report analyses what happens when pensions cross Nordic borders. The analysis shows that pensions are increasingly becoming a genuine border barrier for mobile citizens. Not because national systems are poorly designed, but because they are not interconnected across borders.
“When the pension crosses borders”
Compiled by Resonans Nordic and KPMG Acor Tax on commission from the Nordic Council and the Nordic Council of Ministers.
24 organisations have contributed through interviews, meetings, surveys and written answers.
A survey was also conducted of 910 people with pension rights, experience or expectations to pension issues across Nordic countries.
The report concludes:
“The Nordic pension paradox lies precisely in the fact that the pension systems are strong individually but weak together”.
And for citizens, a lack of coordination between the pension systems creates financial insecurity, unpredictability and sometimes direct financial loss.
Some of the central findings in the report include:
- Mobile citizens come out worse than citizens who have only worked in one country.
- The challenges are structural.
- Complex issues must in practice be handled/solved by individual citizens.
- There is no common data basis to assess the scale of the problem.
“I know that I have some pension in another Nordic country, but I have no idea where to find it.”
Quote from the survey conducted in relation to the report “When the pension crosses borders”
Pension in a confusing landcape
Jakob Rasborg from Resonans Nordic and Maria Louise Berggreen Pihl from KPMG presented the report’s findings to the Freedom of Movement Group and other listeners.
“When labour markets cross borders, we see problems in pension markets too,” they concluded.
“This is extremely difficult and it takes a very long time to get an overview over your own pension. In reality, the complexity is handled by the individual citizen,” said Rasborg.
Their work with the report unveiled that there is little help available for individual citizens, regardless of where and to whom they turn. It is a confusing landscape.
As a consequence, individual citizens are forced to become project leaders for their own pension.
“Each country’s pension system works well, and these are strong pension systems. But they are not designed to work together. The systems are not made for a cross-border labour market,” said Rasborg.
Some of the results from the survey of Nordic citizens who have been working in more than one Nordic country show that:
- Nearly 75 per cent are worried about their own pension
- More than 50 per cent do not have a complete overview of their own pension
- More than 70 per cent have experienced mistakes or delays in connection with pension payments
Citizens face problems both in state and private pensions.
Financial insecurity
One of the report’s most important findings is that a lack of coordination between pension systems creates financial insecurity for mobile citizens.
Taxation of contributions, returns and withdrawals varies considerably between the Nordic countries, and the tax systems are designed according to national logic.
When a pension is accrued in one country and paid out in another, the citizen might face unexpected tax demands, subsequent adjustments or lower pension payments.
“I was taxed in both countries for several months before this was corrected. I had no idea what would be paid out.”
Quote from the survey conducted in relation to the report “When the pension crosses borders”
Where to find information?
The citizen survey and organisational interviews paint a clear picture: What creates the biggest barriers for citizens is not the rules themselves, but the lack of clear communication and transparency in the case process.
Border services often have to serve as unofficial coordinators because citizens cannot get information on their status or rights.
Citizens describe three factors in particular:
- The lack of answers or long waiting times
- Conflicting information from different authorities
- Uncertainty about which agency is responsible
“Everybody said: ‘It’s not here.’ But nobody could tell me who I should really be speaking with.”
Quote from the survey conducted in relation to the report “When the pension crosses borders”
The report’s recommendations
Taxation is the issue which creates the most insecurity and potential losses for citizens in connection with cross-border work.
National differences in the taxation of pension contributions, ongoing returns and payouts can create complex and opaque processes, where the overall taxation depends on place of residence, country of employment, the location of the pension scheme and the timing of the payout.
The analysis indicates that a significant share of the problems that have been identified could be reduced through a revision of the Nordic double taxation agreement, with the aim of mutual tax recognition of occupational pension schemes.
Such a model could be based on a simple, overarching principle:
Tax rules in the country where the pension was established should apply throughout the entire pension period.
Other recommendations from the report, described as “low-hanging fruit”, include strengthened administrative cooperation and the creation of digital access and a Nordic pension navigator.
Calling for more stakeholders to get involved
Kjell-Arne Ottosson is chair of the Nordic Council’s Committee for Growth and Development. When asked by the debate’s moderator André Jamholt what he thought about the findings in the report, Ottosson said:
“I think that I will face a problem when I retire because I have been working in both Norway and Sweden.”
He believes it is unreasonable that individuals have to do so much to secure the correct pension payments.
“It is not reasonable that ordinary people should have to act as project managers for their own pensions simply because our systems do not communicate with one another.
“When you have worked and paid contributions in several countries, it should be the responsibility of the systems to find each other, not the individual,” Ottosson says.
He is also worried that the authorities in the individual countries will not take action to address the problem.
Ottosson encourages everyone affected by the issue to get involved.
“I feel that we can shout ourselves hoarse without getting the message across. We need to bring more stakeholders on board, such as the pension associations. In the end, the authorities have to listen to us.”
Pension among top three worst barriers
Vibeke Hammer Madsen of the Nordic Council’s Border Barrier Council believes that pensions, together with taxation and Nordic e-ID, are the worst border barriers we have in the Nordic region.
All three must be resolved quickly, Hammer Madsen says.
However, based on experience, she knows it is difficult to reach those who ultimately have the power to act; politicians and ministers.
“When I became involved in this work in 2018, taxation was the major issue. We produced an excellent report on the tax problems and how they could be solved, just like this report on pensions.
“We had good discussions with finance ministries and politicians. Then nothing happened,” Hammer Madsen says.
She fears the same will happen now.
“Yes, these are systemic challenges that need to be solved, but it is a political responsibility to do something about them.”
She reminded participants that the Nordic prime ministers are running out of time. There are only three years left until 2030. And the vision is for ‘the Nordic region to become the world’s most sustainable and integrated region by 2030.’
“Ministers must now take responsibility for resolving the three biggest border barriers: taxation, pensions and Nordic e-ID. If they manage to solve these three, there will be hardly any border barriers left in the Nordic region,” Hammer Madsen said.
