In the joint stakeholder feedback by PensionsEurope & AEIP to EIOPA Discussion Paper on a Methodological Framework for Stress-Testing IORPs, we make recommendations on the toolbox of common methodological principles and guidelines but also suggestions for its use in the next IORP stress test exercise in 2022. We support the consideration by EIOPA of the creation of a toolbox and believe that it can allow introducing further proportionality and create a better cost-benefit ratio by considering the specific pension scheme/IORP characteristics in different Member States.

In general, we welcome the EIOPA paper as it recognises the heterogeneity of the IORP sector, the important characteristics of IORPs, and multiple and various criteria for future IORP stress tests. Particularly we support developing cash flow analysis further, as cash flows are the starting point of many tools. For almost all methods mentioned in the EIOPA paper, IORPs would have to use the underlying cash flows to perform the calculations.

PensionsEurope welcomes the opportunity to comment on the consultation regarding the EFRAG Due Process Procedures on EU Sustainability Reporting Standard-Setting.

The European Commission’s proposal for a Corporate Sustainability Reporting Directive (CSRD) envisages the adoption of EU sustainability reporting standards (ESRS). The proposal for a CSRD requires that EFRAG’s Technical Advice is prepared with ‘proper due process, public oversight and transparency, and with the expertise of relevant stakeholders.

Climate change is a pressing political issue that requires swift political action. We note that this urgency is reflected in the consultation paper as well. However, we would like to stress the importance of leaving stakeholders sufficient time to respond to public consultations.

Moreover, the development of sustainability reporting standards is linked to the development of the European Single Access Point. Content-wise, the two projects should be consistent. As a result, we expect regular exchanges ensuring this consistency as well as reaping synergies in the process of developing the future EU Sustainability Reporting Standard. Read our response here.

PensionsEurope welcomes the European Commission’s initiative to assist the EU and Member States in monitoring the adequacy and sustainability of pension systems at macro-level through the development of a pension dashboard. We also support the development of national PTSs and the European Tracking Service project, as we believe that the PTS can be a very powerful tool to make people aware of their financial situation for the old age and can help them to take the right financial decisions. We stress that the PTS is one important element in a retirement system, and it should of course be accompanied by other measures fostering good retirement provisions.

You can read PensionsEurope input to EIOPA on the Development of Pension Tracking Systems here and Dashboards here.