Occupational pensions should be excluded from the scope of the Regulation of the European Parliament and the Council on key information documents for investment products (PRIPS).
A full and unambiguous exemption should be included in the final PRIPS regulation to this extent. a clear disctinction should be made between occupational pensions on the one hand and personal pensions on the other. Occupational pensions are not a "financial product", but are a social benefit the employer offers with an employment contract.
You can find the position paper here.
28 November 2013 - Following its reaction to the Commission's Green Paper on Long-term Investment, PensionsEurope has prepared a position paper on the draft legislative proposal on the European Long-Term Investment Funds (ELTIF). Pension funds and other institutions for occupational retirement provision (IORP) are very suitable long-term investors due to the match with the long duration and maturities of their liabilities. Mutual investment vehicles such as ELTIFs are particularly important for small and middle-size IORPS, since they allow them to invest in long-term projects without jeopardizing the diversification of their asset allocation strategy. You can find the position paper here.
29 October 2013 – In its submission (available here) to EIOPA’s discussion paper on sponsor support technical specifications, PensionsEurope reiterates its opposition to the Holistic Balance Sheet approach. However, given that EIOPA is continuing with this work on its own initiative, PensionsEurope is supplying comments on the technical details of the issues. PensionsEurope acknowledges that EIOPA intends to take proportionality into account through a simplified alternative approach to value sponsor support. However, the approach is deemed far too simplistic and only provide methodology to measure sponsor support with a relatively simple “1-1-1-1” combination (1 sponsor – 1 IORP - 1 pension promise - 1 country). The methodology to value sponsor support with combinations such as multi-employer plans, industry-wide plans, non-profit organisations, public sector IORPs, sponsors with multiple IORPs or IORPs for self-employed people is much more complex and remains understudied, unclear and burdensome. PensionsEurope warns that many IORPs –especially small and medium-sized IORPs - will not be able to make the calculation. Furthermore, PensionsEurope emphasizes the negative consequences that this approach would have on the sponsor companies in terms of investment, job creation and provision of occupational pension schemes.
14 August 2013 - In its submission to EIOPA's consultation, PensionsEurope highlighted the need to adequately define the scope of private personal pensions, clearly differentiating personal pensions from workplace pensions. EIOPA's powers to adopt effective policy actions in this field were also examined, underlying its lack of competence in fiscal matters. Moreover, PensionsEurope recognised that both "passporting" and the so-called "2nd regime" have important advantages but also significant drawbacks. Regardless of which approach is finally followed, it is PensionsEurope’s view that it should be respectful with the existing national personal pension schemes regimes so as to avoid disrupting systems that currently operate satisfactorily. Finally PensionsEurope asked EIOPA to closely coordinate with the different Directorate Generals of the European Commission dealing with personal and occupational pensions in order to ensure consistency across the different on-going initiatives in the EU. You can find the response here.
23 May 2013 - European Commissioner for Internal Market and Services Michel BARNIER said today that solvency-rules should be an improvement for the pensions sector, rather than a punishment. Due to the large diversity in pension systems in Europe, it is impossible to develop good rules that fit all systems in the short term and more research is needed. Consequently, the European Commission will only propose rules for transparancy and governance for IORPs in the fall. Press release
14 May 2013 - PensionsEurope today issued its position paper on the preliminary results of the Quantitative Impact study (QIS). PensionsEurope reiterates its concerns about the Holistic Balance Sheet approach and states that the QIS cannot serve as a basis for an IORP II Directive Proposal. Moreover, PensionsEurope calls for a clear and reasonable new timetable for the whole revision process. Position Paper / Press release.
22 April 2013 - Today, Tjänstepensionsförbundet, the Swedish Occupational Pension Fund Association, joined PensionsEurope. The decision was taken during the General Assembly Meeting in Vienna. You can find the press release here.