On 10 June 2026, PensionsEurope responded to the EIOPA’s discussion paper on integrated data collection. In our response, we made the following points:
Solvency II cannot be used as a legal basis on IORPs
PensionsEurope strongly rejects the Solvency II revised directive as a valid legal basis used to cover the extension of the IORPs’ regulatory reporting, Solvency II clearly legislates that its subject matter and scope are insurance and insurance undertakings, not IORPs. Any implicit convergence between the IORP II and Solvency II frameworks is not correct.
IORPs are different from insurance companies
IORPs operate under different legal framework, the IORP II directive, and fundamentally different business models, governance structures, and supervisory frameworks than insurance companies. Translating Solvency II-like reporting into the IORP II framework adds complexity without supervisory added value, and risks undermining national social and labour law.
Reporting duplication must be addressed
IORPs currently face overlapping reporting obligations arising from the coexistence of reporting frameworks at the national and EU levels, with authorities such as EIOPA, the ECB, and ESMA (for EMIR) often requesting comparable data with different definitions, timelines, and validation rules. PensionsEurope calls for a genuine “report once” principle, where data already available at the EU level — including through EMIR — is reused rather than requested several times in multiple forms.
Proportionality should be further embedded in EIOPA regulatory reporting
Smaller and medium-sized IORPs face disproportionate burdens from current reporting requirements, including complex look-through data requirements and duplicated data fields for derivatives templates that go well beyond their actual exposures. Any future integrated reporting framework must be proportionate to the institution’s size and complexity.
ESG reporting needs rationalisation
Sustainability-related disclosures under IORP II overlap significantly with SFDR and national requirements, creating operational complexity without clear added value. PensionsEurope advocates for a core ESG datapoint set with definitions and calculation rules that can be reused across frameworks.
Get an adequate timeline
PensionsEurope underlines a major timing concern: the revised Solvency II directive requires EIOPA to deliver a report to the EC on integrated data collection by January 2027, while the last iteration of the EIOPA regulation mandates the ESAs to submit a report concerning an integrated reporting system by 11 November 2030. Rushing the IORP analysis to fit the insurance timeline risks producing outcomes that are inadequate for the specificities of IORPs. PensionsEurope calls for the two workstreams to be formally separated.
The simplification agenda should guide EIOPA’s work
EIOPA’s work on integrated data collection should reflect the EU’s stated goal of a 25% reduction in administrative burden and not become a vehicle for increasing the granularity of IORPs’ supervisory reporting. Any future steps must be politically mandated, fully impact-assessed, and firmly grounded in the principles of proportionality and subsidiarity.
Please find our answer to the EIOPA discussion paper below.
