PensionsEurope submitted on October 23 its answer to the EIOPA consultation on an Open Insurance use case. We highlighted our specific model as occupational pensions are not a typical financial product because providers cannot be switched like insurance products as there is a triangular relationship between the employee, the employer, and the pension funds.
In its consultation paper, EIOPA indicated that it does not specifically address the Commission FIDA proposal but suggests that the feedback gathered could help future technical discussions.