AEIP highlights the importance of reusing existing information in its input to EIOPA public consultation on integrated data collection
The European Association of Paritarian Institutions (AEIP) has submitted its response to the European Insurance and Occupational Pensions Authority (EIOPA) public consultation on integrated data collection.
In its response, AEIP welcomes the opportunity to provide feedback on potential inefficiencies, overlaps and inconsistencies in regulatory reporting and disclosure requirements applicable to IORPs. At the same time, given that occupational pension institutions are subject to a distinct regulatory framework and different rules from those applicable to insurance undertakings, we stress that this exercise should have been conducted separately for IORPs, rather than in the context of the requirements for EIOPA to publish a report under Article 35(12) of the revised Solvency II Directive.
IORPs are subject to multiple reporting obligations at both national and EU level, including national supervisory reporting, EIOPA reporting, European Central Bank (ECB) statistical reporting and, for certain activities, the reporting obligations under European Market Infrastructure Regulation (EMIR). In particular, AEIP identified overlaps in the reporting of derivatives, investment exposures and asset classifications, which are subject to different templates, definitions and reporting channels. These overlapping requirements create unnecessary complexity and administrative burden, particularly, for small and medium-sized IORPs, while also increasing implementation costs.
AEIP encourages regulators to prioritise the principle of “reporting only once” and to make greater use of existing data collected by supervisors for other purposes. Such an approach would contribute to regulatory simplification and help avoid the introduction of reporting structures for occupational pension institutions similar to those used under the Solvency II Directive, which would overlap with existing requirements already in place under national social and labour legislation.
AEIP also underlined inconsistencies between ESG-related reporting obligations, particularly those arising from the Sustainable Finance Disclosure Regulation (SFDR) and the IORP II Directive. In this context, we call on EU policymakers and regulators to improve the alignment of the two regulatory frameworks and provide greater clarity regarding their objectives in the context of the ongoing legislative revision.
To read our full response, please see here.