PensionsEurope welcomes the European Commission public consultation on fitness check on supervisory reporting. We find it important that the Commission regularly conducts fitness checks on supervisory reporting to ensure that the ESAs work effectively, and supervisory activities remain proportionate in their scope.
In general, pension funds are embedded in national social and labour law and supervisory reporting should take into account specificities of pension funds, National Supervisory Authorities are responsible for supervising pension funds, supervisors should consider very carefully which information is really relevant and needed (as reporting and collecting information always result in cost), and supervisors and policymakers should not have a bank bias towards pension funds.
Please find PensionsEurope answer to the EC consultation here.
PensionsEurope published today a position paper on smoothing WHT procedures beyond Code of Conduct - EU tax register of recognised pension institutions. In our paper, we propose to the European Commission to establish an EU tax register of recognised pension institutions in order that Member States can reciprocally and automatically recognise pension institutions. Furthermore, in many countries pension institutions invest cross border via specialised investments funds and/or vehicles to increase the economies of scale, and it is important to ensure a tax-neutral treatment of these investment structures as well.
PensionsEurope today published a position paper with its views on the review of the mandate of the European Supervisory Authorities (ESAs).
In our paper, we highlight the fact that pension funds do not fall under a harmonised European framework. National supervisors are therefore best equipped to take into account the specificities of pension funds, which are embedded in domestic labour and social law. This means that there less scope for supervisory convergence for pension funds and the mandate of EIOPA should reflect this. As pension funds are not directly supervised by the ESAs, they also feel they should not contribute directly to their budgets through industry fees.
Moreover, the governance structure of EIOPA should ensure that decision-making is underpinned by sufficient expertise in the area of pensions. We feel that individual stress test results of IORPs should not be disclosed and the Board of Supervisors should remain the decision-making body for the stress tests.
Finally, we welcome a bigger focus on better regulation and a stronger role for the Stakeholder Groups.