Insurance Europe has published its response to
a consultation by the European Insurance and Occupational Pensions Authority
(EIOPA) on its draft technical advice to the European Commission on the
development of pension dashboards and data collection.
Insurers support transparency and agree with
the objective of having a clearer picture of the current pension savings
landscape. However, it is concerning that EIOPA’s proposals seem to ignore the
fact that pensions are, to a large extent, a purely national issue. There is therefore
no single approach to achieving pension adequacy and sustainability, and the
lack of agreed EU definitions prevents meaningful harmonised reporting.
Moreover, EIOPA’s proposals to collect more
data would burden both pension providers — and specifically insurers — and
national authorities with significant extra costs. Furthermore, these proposals
go far beyond the scope of the Commission’s call for advice, namely the
development of pension dashboards.
Therefore, before EIOPA recommends additional
data collection, it should first consider the data, indicators and benchmarks
that are already available at national level. It is also important for EIOPA not
to confuse “availability” with the “comparability” of data. In EIOPA’s draft
technical advice, it often says that data is not available, whereas in fact
very often the data is available but only at national level.
The insurance industry also wishes to express
reservations about some of EIOPA’s objectives in relation to a pension
dashboard. While monitoring of national pension systems is crucial, comparing
and ranking national systems is not a desirable goal.