PensionsEurope Position Paper on the proposal for an IORP II Directive

06 October 2014

PensionsEurope welcomes that the proposal for an IORP II Directive does not contain new solvency capital requirements for IORPs. This would be very detrimental to the occupational pension sector, the members and the beneficiaries.

PensionsEurope are concerned about EIOPA’s upcoming work with regards to the Holistic Balance Sheet approach. EIOPA is currently working on a Quantitative Impact Study and a pan-European stress-test for Institutions for Occupational Retirement Provision (IORPs). PensionsEurope reiterates its opposition to the harmonization of solvency capital requirements. 

PensionsEurope also welcomes the Directive’s improvement on investment rules and the fact that Member States cannot restrict IORPs from investing in long-term instruments that are not traded on regulated markets. PE welcomes that the Directive proposal provides that the competent authorities of the host Member State cannot lay down further investment rules for assets which cover technical provisions for cross-border activity.

However, PensionsEurope is convinced that important features of the occupational pension sector need to be adequately taken into account in the Directive proposal. These main issues include:

• IORPs are first and foremost institutions with a social purpose;
• The overall pension system must be considered;
• IORP II should recognise all types of occupational pensions;
• PE is opposed to the proposed use of delegated acts in this Directive;
• The EC did not take time to provide a sound impact assessment for the Directive;
• Prudential supervision of IORPs should acknowledge that IORPs have a social purpose;
• IORP II Directive is a recast Directive. Therefore, only the changes proposed by the European Commission should be discussed.

Full position paper

© PensionsEurope