INVERCO represents the Spanish Asset Management industry and submits this response to the Call for Evidence to highlight areas where simplification can reduce regulatory overlap, strengthen proportionality and support innovation while safeguarding investor protection. Our full response is set out in greater detail in the attached document, but please see below a summary of our main points.
INV
INVERCO
Other · Spain · EU Transparency Register 648651917120-02
14
positions filed
in the 665 files tracked
8
legislative files
of 665 tracked
14
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1518 trade and business associations on this site, they rank #405 by legislative files engaged, a count of participation, not a measure of influence.
1.2
declared lobbying FTE
self-declared
€100K+
declared costs / yr (floor)
0
EP accreditations
as declared to the register
2015
in the register since
Declares membership of
- https://www.inverco.es/11/17/79
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Trade and business associations
- Registered as
- Asociación de Instituciones de Inversión Colectiva y Fondos de Pensiones (INVERCO)
- Head office
- Madrid, Spain
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
INVERCO filed 14 positions between 11 Dec 2017 and 6 Apr 2026, across 8 of the 665 legislative files tracked here, attaching a full position paper 14 times.
2017 · 1 filed2018 · 3 filed2021 · 1 filed2025 · 4 filed2026 · 5 filed
What they argued
Inverco supports that the sustainability perspective of investment advisory services and discretionary portfolio management services should fall outside the scope of the SFDR. As investment services, and in the interest of greater simplification and consistency within the regulatory framework, this should be fully addressed under MiFID.
INVERCO is the Spanish Association of Collective Investment Institutions and Pension Funds. It represents more than 860,674 million euros in assets under management, channelling the savings of 24 million unit-holder accounts in Investment Funds and Investment Companies and more than 10 million in Pension Funds.
INVERCO is the Spanish Association of Collective Investment Institutions and Pension Funds. It represents more than 860,674 million euros in assets under management, channelling the savings of 24 million unit-holder accounts in Investment Funds and Investment Companies and more than 10 million in Pension Funds.
I. INTRODUCTION INVERCO is the Spanish Association of Collective Investment Institutions and Pension Funds. It represents more than 860,674 million euros in assets under management, channelling the savings of 24 million unit-holder accounts in Investment Funds and Investment Companies and more than 10 million in Pension Funds.
In INVERCO´s view, the purpose of these proposals is valued very positively, since to the extent that the capital flows are directed more easily towards activities that positively impact on the fulfillment of environmental, social and governance objectives, the recipients of said financing will conduct their model of business towards these objectives.
In INVERCO´s view, the purpose of these proposals is valued very positively, since to the extent that the capital flows are directed more easily towards activities that positively impact on the fulfillment of environmental, social and governance objectives, the recipients of said financing will conduct their model of business towards these objectives.
The purpose of these proposals is valued very positively, since to the extent that the capital flows are directed more easily towards activities that positively impact on the fulfillment of environmental, social and governance objectives, the recipients of said financing will conduct their model of business towards these objectives.
INVERCO supports the need to improve undertakings' disclosure of social and environmental information, as well as, developing positions towards considering ESG aspects and integrate them on a voluntarily basis in their asset allocation decisions. Nevertheless, “comply or explain” should be the fundamental transparency principle.
INVERCO is the Spanish Association of Collective Investment Schemes and Pension Funds. It is a non-profit organization representing more than 980.7 billion in assets under management, channelling savings from nearly 27 million unit-holder accounts in Investment Funds and Investment Companies and 10.4 million in Pension Funds.
INVERCO is the Spanish Association of Collective Investment Schemes and Pension Funds. It is a non-profit organization representing more than 980.7 billion in assets under management, channelling savings from nearly 27 million unit-holder accounts in Investment Funds and Investment Companies and 10.4 million in Pension Funds.
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).
INVERCO welcomes the opportunity to comment on the intended review by the European Commission (EC) of the Directive on distance marketing of consumer financial services (hereinafter, the “Directive”). INVERCO (Spanish Association of Collective Investment Schemes and Pension Funds) represents more than 5,500 Collective Investment Schemes and more than 2,500 Pension Funds, with assets under management over EUR 570…
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.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.