On 28 November, PensionsEurope submitted its final position paper to EIOPA’s Call for Evidence on the DC Pensions Toolkit. We support EIOPA’s work and underline that there is no one-size-fits-all model in the EU. Any guidance must remain flexible, proportionate and aligned with national systems, social policies and labour-market realities. To strengthen coverage and adequacy, Member States should use effective financial incentives, particularly stable tax frameworks, alongside measures such as auto-enrolment. Matching contributions and simple enrolment can significantly support young and low-income workers, while collective occupational schemes, built on joint financing, efficiency and risk-sharing, continue to deliver the strongest adequacy outcomes.
DC systems must also work better for non-standard workers, the self-employed and those with career breaks, supported by equitable incentives, flexible contributions and tools like national pension tracking systems. Efficiency can be enhanced through economies of scale or outsourcing for smaller providers, with portability balanced against long-term investment strategies. Strong default investment strategies, appropriate decumulation options and a Value for Money approach that goes beyond costs to include returns, risks, governance and service quality are essential. Finally, future regulation should avoid unnecessary burdens and recognise the strengths of collective, not-for-profit DC models in delivering sustainable retirement incomes.
