AEIP replies to the European Supervisory Authorities (ESAs) joint consultation on the first batch of DORA policy products
The European Association of Paritarian Institutions (AEIP) has submitted its input to the European Supervisory Authorities (ESAs) consultation on the first batch of Digital Operational Resilience Act (DORA) policy products.
AEIP commends ESAs for the opportunity to provide input to DORA and acknowledges the significance of a robust governance and risk management system to preempt and mitigate the consequences of ICT-related incidents and threats. AEIP supports DORA and its mission to establish a comprehensive digital operational resilience framework for the financial sector. Nevertheless, we wish to highlight some concerns from the perspective of the paritarian occupational pension funds sector.
In our view, it is paramount that the proposed framework recognises that the social purpose of a pension fund differentiates it from other financial entities, as also stated in the IORP II Directive. Paritarian occupational pension schemes, typically operate under a collaborative model and are established and overseen jointly by social partners.
Setting appropriate requirements is essential to prevent pension funds and regulators from incurring disproportionate and unnecessary costs and administrative burdens. Our concerns primarily revolve around the level of granularity within the regulatory provisions and the need for proportionality in their application.
Simone Miotto, the Executive Director of AEIP emphasized that:
“DORA should incorporate the flexibility to accommodate sector-specific nuances during its implementation. This can be achieved by endorsing a risk-based and principle-based approach to its requirements. This approach entails financial entities adhering to statutory principles and, under regulatory oversight, defining suitable control measures while providing clear explanations for their compliance with DORA.”
AEIP is broadly supportive and acknowledges the significance of DORA. Nevertheless, we advocate for regulatory technical standards (RTS) tailored to the specific characteristics of the occupational pension fund sector. This should result in more focused, purpose-driven requirements for IORPs and ensure proportionate application. Additionally, we recommend an adequately extended transition period to facilitate the effective implementation of DORA. This extension would safeguard against the imposition of undue regulatory burdens on pension funds and prevent any adverse impact on supplementary pension entitlements.
AEIP remains committed to constructive engagement with ESAs and other stakeholders to ensure the successful development and implementation of DORA. We believe that our collective efforts will contribute to the resilience and stability of the European financial landscape.
Please see here to read the full AEIP input.
For further information please contact:
Panayiotis Elia, AEIP Policy Advisor, Pension & Financial Affairs