Exhibit 99.12

Dechert LLP Three Bryant Park 1095 Avenue of the Americas New York, NY 10036-6797 +1 212 698 3500 Main +1 212 698 3599 Fax

October 2, 2026

Board of Trustees

Forethought Variable Insurance Trust

10 West Market Street, Suite 2300

Indianapolis, Indiana 46204

Dear Ladies and Gentlemen:

You have requested our opinion regarding certain federal income tax consequences to each of the portfolios identified on Appendix A attached hereto as an acquired portfolio (the “Acquired Portfolio”), each a separate series of Forethought Variable Insurance Trust (the “Trust”), a Delaware statutory trust, to the holders of the shares of beneficial interest (the “Acquired Portfolio Shares”) of the Acquired Portfolio (the “Acquired Portfolio Shareholders”), and each of the portfolios identified on Appendix A attached hereto as a corresponding acquiring portfolio (the “Acquiring Portfolio”), each a separate series of the Trust, in connection with the proposed transfer of all of the assets of the Acquired Portfolio to the Acquiring Portfolio in exchange solely for shares of beneficial interest of the Acquiring Portfolio (“Acquiring Portfolio Shares”) and the assumption of all liabilities of the Acquired Portfolio by the Acquiring Portfolio, followed by the distribution of such Acquiring Portfolio Shares received by the Acquired Portfolio in complete liquidation of the Acquired Portfolio (the “Reorganization”), all pursuant to the Agreement and Plan of Reorganization (the “Plan”) dated as of September 30, 2026, executed by the Trust on behalf of the Acquired Portfolios and the Acquiring Portfolios.

For purposes of this opinion, we have examined and relied upon (1) the Plan, (2) the facts and representations contained in the letter dated as of the date hereof addressed to us from the Trust on behalf of the Acquiring Portfolios, (3) the facts and representations contained in the letter dated as of the date hereof addressed to us from the Trust on behalf of the Acquired Portfolios, and (4) such

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other documents and instruments as we have deemed necessary or appropriate for purposes of rendering this opinion.

This opinion is based upon the Internal Revenue Code of 1986, as amended (the “Code”), United States Treasury regulations, judicial decisions, and administrative rulings and pronouncements of the Internal Revenue Service, all as in effect on the date hereof. This opinion is conditioned upon the Reorganization taking place in the manner described in the Plan referred to above.

Based upon the foregoing, it is our opinion that for federal income tax purposes, with respect to each Acquired Portfolio and each corresponding Acquiring Portfolio:

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Portfolio Shares and the assumption of all liabilities of the Acquired Portfolio.

We express no opinion as to the federal income tax consequences of the Reorganization except as expressly set forth above, or as to any transaction except those consummated in accordance with the Plan. Without limiting the foregoing, we express no opinion as to the federal income tax consequences of the Reorganization to the Acquired Portfolio with respect to contracts described in

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Section 1256(b) of the Code or stock in a passive foreign investment company, as defined in Section 1297(a) of the Code.

We hereby consent to the filing of this opinion as an exhibit to the Form N-14 and to all references to our firm therein.

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Appendix A