21/06/2023

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    Economics and Finance

    Pension funds play an important role in the long-term financing of the EU’s real economy and contributing to jobs and growth in Europe. The amount of pension funds’ assets invested in the European Economic Area (EEA) differs between Member States and ranges from 45% to over 75%.

    Pension funds increase the amount of market-based financing available to the economy and improve the efficiency of financial intermediation. Countries with a substantial funded pension funds sector tend to have better developed capital markets. Many non-euro area investments can also have a positive impact on Europe indirectly, as many companies or part of their European business is financed via capital markets around the world.

    Growing, developing, and stable economy attracts investments. If investment opportunities in Europe will improve, the stake of the European investments by pension funds will increase accordingly. Implementing the European Commission’s CMU action plan would be very helpful in this respect.

    Monetary Policy

    In July 2021, the ECB published its new monetary policy strategy adopting symmetric 2% inflation target over medium term, which we supported in our input to the ECB.

    In general, we believe that unconventional monetary policies have had effect in many areas, including various positive and negative side effects. This applies for the economy at large, as well as for pension funds more specifically in the form of preventing a (severe) recession, realising relatively good returns but also substantially more expensive liabilities.

    EIOPA IORPs Stress Testing

    Over the past years, PensionsEurope has had good and constructive dialogue with EIOPA on improving its stress testing methodology for IORPs. We liaised closely with EIOPA for their 2022 IORPs stress test exercice.

    Risk management is essential for pension funds and they regularly carry out their own stress tests and scenario analyses (e.g. Asset and Liability Management studies) as part of their own risk management processes.

    The specifications and methodologies of national stress tests differ significantly from the ‘Common Balance Sheet (CBS)’ (Holistic Balance Sheet (HBS)) used in EIOPA’s stress test. The EIOPA stress test is more about testing the resilience of the sector (per country), rather than individual funds, and stability of the financial system as a whole. These outcomes can lead to different and contradictory steering signals for pension funds and for their stakeholders. As a consequence, they can also cause misunderstanding amongst the stakeholders and general public. Many of the practical and methodological problems related to EIOPA Common Balance Sheet (CBS) could be avoided by developing a cash flow analysis further and by replacing the CBS by it.

    The IORP II Directive stresses that the further development at the EU level of solvency models, such as the HBS, is not realistic in practical terms and not effective in terms of costs and benefits, particularly given the diversity of IORPs within and across Member States. No quantitative capital requirements – such as Solvency II or HBS models derived therefrom – should therefore be developed at the EU level with regard to IORPs, as they could potentially decrease the willingness of employers to provide occupational pension schemes. PensionsEurope calls for policymakers and EIOPA to respect this.

    The next EIOPA IORPs stress test exercise will take place in 2025.

    EIOPA & ECB Reporting requirements for IORPs

    Pension funds in Europe are under two reporting frameworks. The January 2018 ECB regulation sets rules to collect statistical data for the euro area on the balance sheets of pension funds and the funds’ members. The ECB will launch in 2025 a review of its requirement requirements for pension funds. 

    On 10 February 2023, EIOPA published the revised reporting requirements for IORPs, applicable as of 1 January 2025 with the following changes :

    • IORPs with less than EU 50 million in total assets are exempted from the full set of reporting as opposed to the previous threshold of EUR 25 million.

    • New data requirements on the quarterly reporting of derivatives and cash flows will be mandatory for IORPs with more than EUR 1 billion of assets under management.

    • The inclusion of information on: (i) high-level, look-through data on all investments in investment funds (including UCITs) as well as information on derivative positions – to fully understand the risk exposures of IORPs and the products they invest in, and (ii) cross-border data – to accurately monitor cross-border relationships. 

    We liaise closely with EIOPA and ECB to advocate for proportionate reporting requirements and to align their reporting rules to lower the burden for pension funds.  

    EU Reporting Requirements

    Economics and Finance
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