We made the terms of our pension funds more precise

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We updated the terms of our pillar II and pillar III funds. The goal of these changes is to bring the terms fully in line with our investment strategy and clarify some unclear wording. The portfolios themselves are not changing.

Tuleva’s fund terms differ from most other Estonian pension funds in one important way: while fund terms usually state what the fund manager may do with savers’ money, ours state what we do. This way, reading our fund terms gives a clear overview of what assets are actually in the portfolio. (1)

Changes in investment restrictions

Compared to eight years ago, when we started Tuleva, more low-cost index funds have become available to us as a fund manager. For example, just 4–5 years ago, we couldn’t include Exchange Traded Funds (ETFs) in our portfolio because their costs were too high. Today, those costs have dropped. As a result, around one third of our stocks fund portfolio is now invested through ETFs. The rest is invested in low-cost traditional index funds, which – unlike ETFs – are not listed or traded on any stock exchange, just like Tuleva’s pension funds.

As we analysed the terms, we realised they didn’t fully reflect our investment strategy in every detail as we had originally planned. That’s why we clarified the wording and aligned the updates with the Financial Supervision Authority. Our investment strategy remains the same. So, what exactly has changed?

  1. One of the key principles we follow when selecting funds for our portfolio is that we only buy and sell fund units in euros. This keeps transaction costs lower.

    Previously, the terms required that fund units must be denominated in euros – meaning the fund’s NAV, performance and costs are calculated in euros. But for an index investor, this doesn’t really matter, since internal accounting has no impact on a fund’s performance or risk. Any fund that invests outside the euro area is exposed to currency risk anyway, because the underlying assets (like company shares) are bought in USD or another local currency. That’s why we clarified the terms: funds in our portfolio must be tradeable in euros.
  2. Another principle we follow is daily liquidity. Our funds must be able to sell their investments quickly. Previously, the terms stated that fund units in our portfolio must be traded on a regulated securities market. But that’s not the only way to ensure daily liquidity. The index funds we hold in our portfolios – even though some of them are not Exchange-Traded Funds – allow us to redeem our units within a few day. That’s why we revised this wording in the terms.

Update to the fund manager’s capital requirement

We also brought the fund terms into line with a change in the law that sets how much of its own money the fund manager must hold in pillar II funds. When we started Tuleva, the requirement was 2% of the fund’s assets. A few years ago, the government lowered it to 0.5%.

Why don’t we set a higher requirement for ourselves? We don’t need to. Most of the money in Tuleva’s pension funds already belongs to the owners of the fund manager – the members of the Tuleva Commercial Association. In addition, the majority of our association’s capital is invested in our own pension funds – as stated in our membership capital terms. That’s why no extra obligation is necessary. (2)

When do the updated terms take effect?

Under the law, changes to fund terms only come into force after unit-holders have had time to review them and, if they wish, leave the fund at no cost. That means:

  • The updated terms of the Tuleva World Stocks Pension Fund and the Tuleva World Bonds Pension Fund will take effect on 1 September 2025.
  • The updated terms of the Tuleva Third Pillar Pension Fund will take effect on 15 June 2025. (3)

Tuleva never charges entry or exit fees. This means you can leave our funds at any time without paying a redemption fee. If you wish to transfer your savings elsewhere before the new terms take effect, please submit your application by: 31 July 2025 for pillar II funds (Tuleva World Stocks Pension Fund and Tuleva World Bonds Pension Fund); 14 June 2025 for the pillar III fund (Tuleva Third Pillar Pension Fund). You can submit your application through your internet bank, at the Pension Centre, or on Tuleva’s website.

The updated terms were approved by the Financial Supervision Authority on 12 May 2025. As a reminder, we also updated the funds’ prospectuses and key investor information documents in March 2025.

Related documents (in Estonian):


  1.  For example, see Swedbank 1970–79 fund terms.
  2. As of the end of April, our fund manager’s own investment represented 1% of the pillar II fund assets.
  3. Under the law, pillar II fund terms can take effect on the next switching day (which is 1.09.2025), and pillar III terms one month after notice is published.
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