In a position paper regarding the European Commission's legislative proposal for the revised IORP Directive, expected sometime this autumn, the German association said the HBS approach was an "inadequate copy-and-paste exercise" from the Solvency II framework for insurers. "The aba calls for the creation of a separate and appropriate supervisory regime for IORPs, which is financially viable and properly takes into account the special characteristics of IORPs", it said.
The association also argued that employers and employees have to commit themselves for several decades under an occupational pension plan, which means "reliable labour, tax and prudential law and regulations are therefore of utmost importance".
It added: "The discussion regarding an application of Solvency II-style capital requirements to IORPs, which we have had for several years now, has led to uncertainties for employers, which, as a consequence, have halted any further developments". It said IORP II should not have the character of a 'transitory' Directive, where it is already clear today that another review will be needed soon. "In other words, initiatives to create new IORPs or develop existing ones further are on hold – a situation that has to end."
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