In our response submitted to EIOPA on 8 September 2021 we argue that developing a Pensions Dashboard is in many ways a political rather than a technical task (building on our position paper regarding Action 9 on pensions of the New Action Plan “A Capital Markets Union for people and businesses” from December 2020). Pension Policy should be driven by the Member States (MS). Within the EU Commission, DG EMPL is best placed to work on pension issues from a social perspective. We therefore agree with EIOPA that the technical advice should not include recommendations on political choices or public policy.

In general, we support the intended macroeconomic view and advocate an approach where data which is already being collected is used for the Pension Dashboard. We therefore welcome the overview EIOPA provides on existing data sources at the international level (Chapter 2). In addition to the data collected for supervisory purposes, the MS should check what kind of pension data are available at the national level for tax, labour or social law reasons. As a next step, it should be determined by the relevant stakeholders how this data could be used in a Pension Dashboard. 

PensionsEurope has also submitted a response, addressing these issues as well.