|
|
PensionsEurope also welcomes that the proposal for a Directive on the activities and supervision of institutions for occupational retirement provisions (hereafter referred to as IORP II) does not contain any reference to harmonised solvency framework. Workplace pensions are based on social and cultural traditions and strongly linked to statutory public (first pillar) pension provision, which differ between Member States. For this reason, PensionsEurope do not believe that quantitative requirements can be harmonised in an appropriate way. IORPs cannot be regulated in the same way as banks and insurance companies.
PensionsEurope regret that the European Commission did not take more time to provide a sound impact assessment for a Directive that will have consequences on millions of members and beneficiaries, employers, IORPs and competent authorities. PensionsEurope question the reliance of the figures put forward by the European Commission. For instance, the potential cost of the Pension Benefit Statement (estimated at €22 per member as a one-off implementation) and the Risk Evaluation for Pensions are difficult to estimate as the details of such requirements will be decided at Level 2, after mapping the already existing similar practices at national level. Therefore, any extrapolation at EU level seems not accurate and not based on facts.
PensionsEurope notes the inflation of articles compared to IORP I Directive and is extremely concerned about the costs arising from the Directive proposal for IORP II which are likely to exceed those foreseen by the Impact Assessment. The one-size-fits-all approach misses the necessary distinction between members and consumers as well as between individual and collective schemes and results for example in an unnecessary overload with regards to information disclosure requirements. In the end, PensionsEurope reminds that the costs will be borne by employers, members and beneficiaries thus lowering the level of pension benefits.