AEIP provided its input to the CMU final report and the recommendations of the High-Level Forum on CMU.
AEIP provided its input to the CMU final report and the recommendations of the High-Level Forum on CMU. In its feedback, the organization stresses that access to objective and free-of-cost company data is one of the major challenges for many market participants and stakeholders in general, so an EU single access point could be a step in the right direction.
AEIP welcomes as a positive development that complementary funded pensions could be taken into consideration for the pension systems’ sustainability and for pension adequacy. However, any reporting system related to this initiative should not increase the reporting burden for occupational pension funds, which are social institutions by nature and contribute significantly to pension adequacy.
The association also states in its feedback that a principle-based, best-practice blueprint by the European Commission that would provide guidance on adequate retirement incomes is welcome. AEIP understands the advantages and strengths of auto-enrolment to pension schemes, since the literature and experience show that it is beneficial for the pension adequacy of individuals. Nevertheless, an EU legislative proposal requiring auto-enrolment at a national level does not seem to be in line with the limited competences of the EU in the social field (Art. 140 EC) as well as with the principle of subsidiarity. In that regard, AEIP would like to stress that each national social protection and pensions system has its own particular characteristics, formed by historical legacy and participation of stakeholders and social partners, so a ‘one-fits-all’ approach is not the preferred way to go forward. In a similar vein, the association strongly opposes the statement that all Directives should be transformed into Regulations, particularly in the case of the IORP II Directive.
We think that the opportunity for supervisory convergence in this specific context is rather limited, convergence of supervisory practices is different in a framework of minimum harmonization. The members of AEIP fall under the provisions of national social and labour law (SLL) and are subject to national supervision. The European Commission and EIOPA should acknowledge their social function and the triangular relationship between the employee, the employer and the institution (IORPs or provident institutions).
Finally, AEIP is very positive towards the creation of a European Tracking System portal.
Please see here the full input of AEIP to the HLF final report on the CMU.