In April 2011, the European Commission asked EIOPA for advice on the EU-wide legislative framework for IORPs (Institutions for Occupational Retirement Provision).
The Commission sought advice on the scope of the IORP directive, on certain cross-border aspects and on three other areas. Firstly, what quantitative requirements should apply to IORPs and how should these be measured? Secondly, what should be the qualitative requirements, particularly in respect of the governance of IORPs? Thirdly, what information should be provided in respect of IORPs to members and beneficiaries, and to supervisory authorities?
The Commission also sought advice on the extent to which the legislative framework for IORPs should be similar to that for other financial institutions and products, in particular the Solvency II framework for insurance and the UCITS IV Key Investor Information Document.
In October 2011, EIOPA published a consultation document on its response to the Call for Advice.
The Society has responded to the consultation. In the response, we note that some elements of the Solvency II framework could have relevance to IORPs, but we also highlight the differences between insurance contracts and IORPs and point out many issues that would require careful consideration if a Solvency II-type framework was to be introduced for IORPs. We note the heterogeneity of pension systems across Europe and we express the opinion that maximum harmonisation in relation to pension scheme governance is not possible.