PensionsEurope submitted on 4 March 2024, its answers to the consultation of the ESAs on the second batch of DORA policy products (4 RTS, 1 ITS & 2 Guidelines). 

PensionsEurope’s answers highlight the lack of proportionality of draft level 2 and 3 measures which would put excessive burdens on IORPs, especially given the short timeframe left before the application of DORA, planned on 17 January 2025. PensionsEurope also advocates for different reporting timelines depending on the type of financial entity, given the specificities of IORPs which are often small-size structures and not-for-profit organisations.

Furthermore, it is also important to notice that the systemic nature of IORPs is lower compared to other financial entities and should therefore lead to a more cautious approach for IORPs regarding TLPT processes.

The ESAs are now assessing the stakeholder’s feedbacks before submitting their final reports to the EC by 17 July 2024.