On 14 October, PensionsEurope responded to the EC call for evidence on the digital omnibus package. We emphasized the need for a principle-based approach to address the specificities
of IORPs, which differ from those of other financial entities, given that occupational pensions are managed through social partners. We also pointed out the importance of strengthening the application of the principle of proportionality, as smaller and less complex entities such as IORPs should not be subject to the same obligations as systemically critical players.
We also advocate for DORA simplification in the field of major ICT incidents reporting and subcontracting requirements to deliver genuine regulatory simplification while fully maintaining the objectives of operational resilience and supervisory objectives.
The EC will publish its digital omnibus package on 19 November 2025.
For more details, see our answer below.
