Pan-European Personal Pension Product (PEPP)

ALFI supports the European Commissions efforts to strengthen supplementary pensions and welcomes the work on the Supplementary Pensions Package, as part of the Savings and Investments Union, and here in particular the review PEPP Regulation. A workable PEPP product will play a part in strengthening pension systems with funded pensions for cross border workers. ALFI welcomes the removal of the 1% fee cap.

NVERCO is the Spanish Association of Collective Investment Schemes and Pension Funds. It represents more than 980.7 billion in assets under management, channelling savings from more than 27.3 million unit-holder accounts in Investment Funds and Investment Companies and 10.4 million in Pension Funds. (data from December 2025).

Pension funds should have a shareholder structure, to hold the shareholders’ meeting with direct participation at least 1 times a year without the undemocratic closure of Meloni’s fascist government in Italy.

Filed in Italian · English published by the European Commission

BNP Paribas Cardif supports initiatives aimed at developing pension savings products in Europe. Strengthening and expanding supplementary pensions is essential to improve retirement outcomes in the context of pressure on public pension systems, but also to deepen capital markets and unlock long term investments.

BETTER FINANCE welcomes the Commissions proposals to amend the Regulation on a Pan-European Personal Pension (PEPP) product. As longtime supporters of the PEPP, we are pleased to see that the Commission remains committed to ensuring that a simple, cost-efficient personal pension product (PPP) is made available to EU citizens to complement the existing offer of PPPs in each Member State.

FECIF welcomes the European Commissions initiative to revise the PEPP Regulation, in light of its very limited market uptake. Experience to date shows that, in its current design, the PEPP has failed to establish itself as a viable market product, due to rigid cost requirements, regulatory complexity, lack of sustainable product and distribution models, and insufficient incentives for providers.

Assogestioni welcomes the European Commissions review of Regulation (EU) 2019/1238 on a pan-European Personal Pension Product, supports the broader objective of strengthening individual retirement savings across the Union and recognises the potential value of a simple, transparent and portable personal pension framework at EU level. In this context, the PEPP remains a worthwhile policy initiative.

Unipol welcomes the opportunity to provide feedback on the Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2019/1238 on a pan-European Personal Pension Product (PEPP Regulation). We wish to commend the Commission for this initiative, as in our view the current PEPP Regulation needed significant revisions.

For a more detailed explanation of the considerations set out below, please refer to the attached position paper. VOTUM welcomes the European Commissions decision to review the PEPP framework in light of its very limited market uptake. The experience of recent years has shown clearly that, in its current form, the PEPP has not developed into a viable market product.

Assoreti is the Italian Association of intermediaries which provide investment advice services through their financial advisors authorised to operate off-premises (tied agents who are natural persons). First and foremost, it wishes to express its appreciation for the measures being undertaken to rationalize and simplify the financial regulatory framework, also with a view to a more competitive European market.

Supplementary pensions are important, but there is no need for an EU-level pension product Finance Finland supports the European Commissions objective to promote supplementary pension markets. Finance Finland notes that there is a need to supplement pension provision in Finland as well, despite the strong statutory earnings related pension system.

Our association already participated in the European Commission’s consultation on supplementary pensions in Europe in August 2025, commenting on the planned revision of the PEPP Regulation. In this consultation, the Commission unquestionably acknowledged why the introduction of the pan-European Personal Pension Product (PEPP) has so far not been successful.

Filed in German · English published by the European Commission

The Pan-European Personal Pension Providers Association (PEPPPA) welcomes the European Commissions proposal to revise the PEPP Regulation with the aim of improving its attractiveness, scalability and role within the Savings and Investments Union.

The fact that certain issues regarding PEPPs have been acknowledged is certainly a positive development; however, the proposal as a whole remains unsatisfactory. The product should be much more accessible, especially for young people and for workers who move frequently between different countries. Furthermore, significant concerns remain regarding the overall structure of the initiative.

EFPA Europe, a non-profit organisation certifying over 100,000 financial advisers across 15 countries, welcomes the European Commissions proposal to reform the Pan-European Personal Pension Product (PEPP). European pension systems face increasing pressures from ageing populations, longer life expectancy, and changing labour markets.

We agree with the importance of revising the current framework of pan-European Personal Pension Product (PEPP) in order to make it more flexible and attractive and thus allowing a more dynamic market able to meet the individual needs of savers.

The BPCE Group’s insurance division comprises personal insurance and non-life insurance activities for customers of Banques Populaires and Caisses Dépargne, as well as guarantees and financial guarantees, which are also offered to direct customers.

Filed in French · English published by the European Commission

The introduction of high-yield, share-based, and simple supplementary pensions is crucial to achieving the goals of the Savings and Investments Union. These pensions enable people to participate in the success of the European economy and increase their retirement income. At the same time, funds flow through the pension system into the European economy to finance growth, innovation, and employment.

The European Commissions proposal on the review of the Pan European Personal Pension Product (PEPP) is an important step in the right direction. With the right changes a modernised PEPP can help citizens build sustainable retirement income. To this end, PEPP must become a label that is recognised by European citizens.

The Deutsche Aktuarvereinigung e.V. (DAV) (German Actuarial Association) welcomes the initiative of the European Commission to review the PEPP Regulation and supports the objective of further enhancing the attractiveness, transparency and practical applicability of the Pan-European Personal Pension Product.

The Actuarial Association of Europe (AAE) welcomes the Commissions initiative to review the PEPP framework with the objective of improving its attractiveness, scalability and usability as a long-term retirement saving solution.

The Pan-European Personal Pension Product (PEPP) was launched in 2019 with high hopes of providing a simple and portable retirement savings plan across the EU. However, since PEPPs became available in 2022, uptake has been disappointingly low, by the end of 2025, only two providers had launched a PEPP across the entire EU.

The European Real Estate Association (EPRA) is the voice of Europes listed real estate companies, their investors, and suppliers. With more than 290 members covering the entire spectrum of the listed real estate industry, EPRA represents over EUR 940 billion in real estate assets and 95% of the market capitalisation of the FTSE EPRA Nareit Europe Index.

Allianz supports the objective of boosting supplementary pensions to help secure adequate retirement income, by improving access to better and more effective supplementary pensions. As such, Allianz welcomes the EU Commissions ambition to make the Pan-European Pension Product (PEPP) more attractive to providers and better adaptable to customer preferences.

The text clarifies that, "within the prudent person principle, PEPP providers shall take into account risks related to and the potential long-term impact of investment decisions on ESG factors". We welcome the explicit inclusion of ESG risk in the prudent person principle. We stress the relevance of the requirements for PEPP providers to consider the long-term impact of their investment.