On March 3, 2023, the European Insurance and Occupational Pensions Authority (EIOPA) published its consultation paper on the European Commission's Call for technical Advice on the review of the IORP II Directive and made it available for consultation until May 25.

In its detailed statement, aba advocates, inter alia, to preserve the character of IORP II as a minimum harmonization directive: Many of the proposals formulated by EIOPA would go significantly beyond this if implemented, e.g. by adopting provisions from full harmonization directives such as Solvency II and anchoring EIOPA Opinions in the directive. aba does not consider EIOPA´s proposals on proportionality to be helpful.

Furthermore, aba is in favor of continuing to take into account the central role of representative bodies in collective pension schemes. This representative democracy, which is customary in IORPs, leads to good and transparent results. The queries of individual preferences (e.g. with regard to risk appetite) envisaged by EIOPA for various topics contradict the proven effective governance of collective systems. A direct transfer of requirements from financial market regulations is neither sensible nor appropriate.

PensionsEurope, supported inter alia by aba, also contributed to the EIOPA consultation with a detailed statement. Furthermore, other members of PensionsEurope have also contributed directly and/or indirectly to this discussion. The European insurance association InsuranceEurope has also submitted a statement.

EIOPA will prepare the final advice to the EU Commission in the coming months and submit it by October 1, 2023 at the latest.