Responding to the consultation paper on the QIS launched by the European Insurance and Occupational Pensions Authority (EIOPA) in June, the pension industry in the UK voiced concerns over the "narrow" scope of the impact study exercise as well as the tight timetable imposed by the European Commission, giving EIOPA an "impossible task" to conduct.
According to the National Association of Pension Funds (NAPF), the six-week period allowed for the present consultation was "completely inadequate" for careful consideration of the complex issues raised, as it did not allow stakeholders to get detailed input from technical experts.
"NAPF recognises that EIOPA's timetable is largely driven by the European Commission's objective of delivering a draft Directive by summer 2013", the association conceded. "But EIOPA – as the EC’s adviser – should make it clear that more time is needed to test policy options and develop a sound policy proposal."
Beyond those concerns, Towers Watson also argued that EIOPA had to make a large number of technical assumptions about how assets and liabilities should be valued and it was not clear whether all of the ensuing consequences were intended. "It appears that the contributions employers make to pension schemes can sometimes have the paradoxical effect of increasing the deficit on the proposed new funding measure rather than reducing it."
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