PensionsEurope

PensionsEurope's position paper on the EC digital omnibus regulation proposal March 2026 www.pensionseurope.eu PensionsEurope acknowledges the Commission’s initiative to simplify the EU digital rulebook through the digital omnibus package.

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

PensionsEurope's answer to the EC call for evidence on the digital omnibus package October 2025 www.pensionseurope.eu We acknowledge the Commission’s initiative to simplify the EU digital rules, while the full implications still need to be clarified.

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

PensionsEurope welcomes the opportunity to comment on the proposal of the European Commission for a Corporate Sustainability Due Diligence Directive. PensionsEurope supports the objectives of the OECD Guidelines on Responsible Business Conduct, to which a large number of pension funds have already voluntarily committed.

PensionsEurope supports the European Commissions objective to simplify SFDR 2.0, but cautions that the proposed categorisation system is structurally misaligned with occupational pensions. Unlike retail product manufacturers, Institutions for Occupational Retirement Provision (IORPs) are long-term institutional investors and customers of financial products, operating under fiduciary duty and liability-driven…

PensionsEurope welcomes the opportunity to comment on the proposal of the EU Corporate Sustainable Reporting Directive (CSRD). IORPs as investors are users of the data which companies will be required under the legislative proposal for a Corporate Sustainability Reporting Directive.

PensionsEurope welcomes this EC call for evidence initiative that aims to identify reporting requirements in EU legislation that can be removed or rationalized without undermining the policy objectives of the EU. Pension funds are important due to their social role.

PensionsEurope welcomes the opportunity to comment on the Communication on the competitiveness of the EU banking sector published on the 17 July 2026. PensionsEurope acknowledges the importance of building a more integrated, efficient, and competitive banking sector that can strengthen Europe's economy.

PensionsEurope welcomes the the Commission's proposal for a framework for Financial Data access (FIDA) which is a key component of the Commission's digital finance strategy presented in September 2020. We also would like to highlight that experiences from other financial services such as payment services cannot be simply applied to the Institutions for occupational retirement provision (IORPs) which are included in…

PensionsEurope welcomes the European Commissions proposal on ESG ratings. This legislation provides many solutions to current market shortcomings, such as enhancing transparency on methodologies and operations, regulating conflict of interests, establishing rules for third-country providers, and providing specific measures for smaller ESG providers.

PensionsEurope welcomes the European Commission's proposal for a Faster and Safer Relief of Excess Withholding Taxes (FASTER). As cross-border investors, with 2.4 trillion euros of assets for EEA institutions for occupational retirement provision (IORPs) at the end of 2022, pension funds bear witness to investment barriers and costs within the single market which ultimately impact negatively pension fund members and…

We welcomes the EC’s roadmap on the new EU system for the avoidance of double taxation and prevention of tax abuse in the field of withholding taxes (WHT). We support the current EC´s mandate call for removing all barriers to the completion of the CMU – particularly in the field of simplifying taxation.

PensionsEurope welcomes the opportunity to provide input to the European Commissions consultation on the review of the Shareholder Rights Directive II (SRD II). At the same time, we underline the importance of preserving an appropriate framework for pension funds as long-term investors.

As the European umbrella organisation representing pensions in Europe, PensionsEurope would like to comment on the European Commission Proposal for a Council Directive laying down rules to prevent the misuse of shell entities for tax purposes and amending Directive 2011/16/EU. Please find our comments in the attached file.

Read attached PensionsEurope's complete feedback. In summary: PensionsEurope supports the EC’s objective to simplify the life of taxpayers operating in the Single Market and we welcome the review of the VAT rules.