PensionsEurope welcomes the opportunity to comment on EIOPA’s Consultation paper on the creation of a standardized Pan-European Personal Pension product (PEPP). While the first and the second pillar should provide the bulk of the retirement income, personal pensions (third pillar) can be a useful instrument to further top up the retirement income and contribute to securing the future adequacy and sustainability of pensions.
PensionsEurope would like to highlight a key feature of Personal Pension Products which it believe should be used to distinguish private personal pensions from private workplace pensions:
- Private personal pensions are not linked to a context of occupational activity, such as a current or previous employment relationship. This characteristic is outlined by the OECD in its revised taxonomy for pension plans, pension funds and pension entities when defining private personal pension schemes. It would also be in line, for instance, with the current situation in some countries such as Belgium: when a Belgian employee ends his for EU citizens. This could certainly also contribute to a reinforcement of the internal EU capital market. In this respect, it should be taken into account that (compulsory) funded workplace occupational pension schemes are by nature very well suited to serve as providers of long-term capital. Finally PensionsEurope would like to stress that if the idea of a ‘2nd regime’ would be pursued, it is important to test the demand and also to elaborate further on the reasons why such a system is deemed needed in addition to the many personal saving products already in existence.
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