In our input to EIOPA, we find it important that financial entities can be unequivocally identified, and we agree that it would be useful to have one worldwide identifier for that purpose. PensionsEurope would like to thank EIOPA for having considered proportionality in its draft guidelines on the use of Legal Entity Identifier, and we agree with the EIOPA proposal.
In general, we find proportionality of the utmost importance when introducing any new requirements to IORPs. Particularly the current low/negative yield environment has made small IORPs very sensitive to any additional fixed costs, on top of the already existing investment, administration, governance, and communication costs.
