Strengthening of the framework for occupational retirement provision

1. General Reflection on the Regulatory Package on Supplementary Pensions INVERCO views the European Commissions (EC) regulatory package on supplementary pensions as very positive initiative, given that it is essential to address the issue of an aging population in the European Union and its impact on public pension systems.

BETTER FINANCE welcomes the Commissions proposed amendments to the IORP II framework. Occupational pension schemes hold great potential to improve European citizens retirement income as well as to deepen the EUs capital markets, which we believe the proposed amendments will contribute to realise.

ARBEITSGEMEINSCHAFT BERUFSSTÄNDISCHER VERSORGUNGSEINRICHTUNGEN e. V. ABV e. V. - Luisenstraße 17 - 10117 Berlin GESCHÄFTSFÜHRUNG An die Europäische Kommission Postfach 08 02 54 10002 Berlin Telefon [phone removed] Telefax (030) 8009310-29 E-Mail [email removed] Internet www.abv.de Brüssel, 6.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Federation of Insurance Intermediaries BIPAR Aisbl Avenue Albert-Elisabeth, 40 - 1200 Brussels – Belgium Tel: +32-2-735.60.48 - [email removed] - www.bipar.eu EU Transparency Register ID: 349128141758-58 Company no: BE 0562 817 754 BIPAR Response to EC Consultation on its Review of the EU legislative framework for institutions for occupational retirement provision March 2026 BIPAR is the European…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

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.

Unipol welcomes the opportunity to provide feedback on the review of the IORP II Directive We appreciate the initiative taken by the Commission in this field, as the European supplementary pensions sector demands intervention aimed at strengthening the protection of EU citizens and fostering the soundness of EU financial markets.

Assogestioni welcomes the review of Directive (EU) 2016/2341 as a timely opportunity to strengthen the occupational pensions sector and support the development of supplementary pensions, better retirement outcomes and the mobilisation of long-term savings for productive investment.

SGI Europe welcomes the European Commissions Pensions Package, including the proposal to revise the Directive on Institutions for Occupational Retirement Provision (IORP II) and the review of the Pan-European Personal Pension Product (PEPP) Regulation, as well as the accompanying Recommendation on pension tracking systems, dashboards and auto-enrolment.

The proposed revision of the IORP II and IDD directives is part of a process aimed at progressively strengthening European supervisory authorities, a move that nevertheless raises significant concerns. The transfer of powers from Member States to the European level risks upsetting the institutional balance and reducing the scope for national autonomy, with potential implications for democratic legitimacy as well.

EAPSPI welcomes the ECs initiative to strengthen occupational pensions within the framework of the review of the IORP II Directive. However, it must be said that the current draft only partially achieves this goal.

We agree with the importance of revising the current framework of occupational retirement provision in order to boost supplementary pensions by making it easier for people to access such pensions and strengthening the capacity of pension schemes (occupational pensions and personal pension plans) to invest efficiently and achieve better investment outcomes.

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 draft revision of the EU framework for institutions for occupational retirement provision (IORPs) touches upon key issues of pension provision, risk sharing between public, occupational and private provision, governance and suitability requirements for management bodies.

Filed in German · English published by the European Commission

We fully support the objective of promoting broader access to occupational pension schemes. With their extensive experience, IORPs are well positioned to contribute to the expansion of occupational pension provision. According to EIOPA, in the fourth quarter of 2024, European IORPs had 74.1 million members and held 2.69 trillion in investments (around 9 % from Germany).

Filed in German · English published by the European Commission

The Actuarial Association of Europe (AAE) welcomes the opportunity to respond to the European Commission's proposal on IORP II. Actuaries are essential to sound risk management, financial stability, and the long-term resilience of the European pension sector. We support the Commissions aims to encourage long-term investment and reduce unnecessary burdens, while ensuring adequate retirement income.

The Dutch Fund and Asset Management Association (DUFAS) welcomes the European Commissions proposal of 20 November 2024 to boost supplementary pensions and help ensure adequate retirement incomes across the EU. This comprehensive package includes non-binding recommendations for Member States on pension tracking systems, pension dashboards, and auto-enrolment, as well as two legislative proposals to amend the IORP II…

The text clarifies that, "within the prudent person principle, IORPs shall take into account sustainability risks, as defined in Article 2, point (22), of Regulation (EU) Council 2019/2088 and of the European Parliament in their investment decisions".