On 26 July 2017 the European Central Bank (ECB) launched a public consultation on the draft ECB Regulation on statistical reporting requirements for pension funds (“the draft Regulation”), which lays down requirements for the collection and reporting of pension funds statistics.
Euro area pension funds have around 50 million members. Pension funds are among the largest and fastest-growing investors in global capital markets. In order to increase the transparency of pension funds for the benefit of their members, the general public and the economy as a whole, the ECB is introducing a new ECB regulation on the collection of pension fund statistics.
From the outset of the project the ECB has carefully assessed the potential impact of the proposed draft Regulation, with a view to containing the costs incurred in compliance. Through sustained cooperation with national central banks (NCBs) and, via them, with reporting agents and their industry associations, the ECB applied its “merits and costs procedure” in accordance with the principles and procedures set out in Council Regulation (EC) No 2533/981 to ensure that the reporting burden on pension funds is contained and that the data are collected and compiled in a costeffective way.
To this end, and taking into account the proportionality principle in particular, the reporting requirements as set out in the initial proposal have been significantly streamlined, especially for smaller pension funds.
Pension funds will also report to the European Insurance and Occupational Pensions Authority (EIOPA). With a view to minimising the reporting burden for the industry, the relevant EIOPA and ECB bodies have cooperated closely to set up the definitions, the methodological framework and the preparation of the transmission format for both ESCB statistics and supervisory reporting. A very high level of convergence between these reporting requirements and the data content and other features of the draft Regulation, such as timeliness and coverage, has been achieved. This will allow a single data flow for reporting by the industry, should this be decided at the national level by the respective NCBs and national competent authorities (NCAs).
Following the public consultation and the response from the European Commission, the ECB analysed and gave due consideration to all comments received and subsequently amended the draft Regulation.
The most fundamental changes are:
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a postponement of the first reporting deadline;
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an increase of the reporting threshold from €10 million to €25 million (in respect of total assets), coupled with a transitional approach to reach the 80% coverage of total assets by 2022, but coverage at the level of at least 75% of total assets must be reached during this period;
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a phasing-in period for alignment with EIOPA’s supervisory reporting requirements;
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a clarification of the term “pensions fund managers”.
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