In its answer to the to the European Commission consultation on the operations of the European Supervisory Authorities, PensionsEurope e.g. stresses that the current powers and tools of the ESAs are more than sufficient related to IORPs. Taking into account the fact that IORPs are built on a foundation of national social, labour and tax law, they should be mainly supervised by national supervisory authorities.
PensionsEurope is not in favour of granting additional powers to EIOPA to require more information from IORPs. New requirements should be introduced only if the expected benefits clearly outweigh additional costs.
IORPs should not be treated as purely financial service providers. Their social function and the triangular relationship between an employee, an employer, and an IORP should be adequately acknowledged and supported by the ESAs.
The ESAs should refrain from impinging upon the right of initiative of the European Commission to come up with new legislative initiatives that go beyond the existing framework of the single rulebook. As an example, we would like to draw attention to the efforts of EIOPA towards a pan-European occupational DC framework (in the second pillar).
PensionsEurope finds that it was a good decision to create two stakeholder groups within EIOPA (the Insurance and Reinsurance Stakeholder Group (IRSG) and the Occupational Pensions Stakeholder Group (OPSG)). This division enables the OPSG to properly discuss issues relating to occupational pensions.