AEIP submitted its feedback to the European Commission’s proposal for a Regulation on a framework for Financial Data Access (FiDA)
The European Association of Paritarian Institutions (AEIP) has submitted its feedback to the European Commission’s proposal for a Regulation on a framework for Financial Data Access (FiDA). Acknowledging the Commission’s commitment to advancing digital finance, AEIP emphasizes the need for a more precise definition of the framework’s scope and the potential obligations that it may impose on the pension fund sector. In our opinion, the current proposal does not adequately address the unique characteristics of the pension funds and there is a risk of misalignment with existing national rules and procedures for pension data sharing, i.e., pension tracking services.
Simone Miotto, the Executive Director of AEIP said:
“We believe that it is crucial rules and procedures of this Regulation make it possible for pension tracking services to operate data sharing within the FiDA framework. AEIP expresses caution about introducing data standards or technical specifications that deviate from current practices, as this may necessitate the establishment of a parallel data sharing infrastructure. Such a situation would create financial and administrative challenges, particularly for small and mid-sized pension funds, resulting in additional financial burdens on their members and beneficiaries, ultimately diminishing pension benefits.”
AEIP appreciates the stakeholder-driven approach of fostering cooperation among financial institutions for financial data sharing schemes. Nevertheless, AEIP suggests that data holders should be primarily responsible for developing FiDA data standards and technical specifications, with data users contributing to the functional design without decision-making authority. Furthermore, policymakers should consider the cyclical nature of pension administration when determining data update frequencies; a delay in updating pension data should be acceptable.
We welcome the exclusion of health and sickness data from the scope of the proposal, and we advise to exempt disability pension to mitigate financial exclusion risks. Moreover, AEIP suggests clarifying that potential beneficiaries of a survivor’s pension are not members of pension funds.
AEIP supports the notion that customer data sharing should be consent-based, with the data subject retaining control over the data they share. Furthermore, we welcome that data exchanges should adhere to legal obligations and be duly justified.
To read our full feedback to the FiDA proposal see here.