PensionsEurope prepared a new set of messages on FIDA, ahead of the trilogues. We indicated our satisfaction that co-legislators broadly acknowledged the specificities of occupational pension schemes that are often managed by social partners and depend on the employer’s affiliation. The Council’s exclusion of the “pension rights in official recognised occupational pension schemes” customer data category from FIDA’s scope is a very positive step. We also welcome the creation of a Member State opt-in system for the same customer data category that would give the possibility for Member States to include the category in the scope if they wish to do so while preserving the exclusion and properly considering the diversity of the EU occupational pension landscape.
However, we also expressed our concerns regarding the Council position that includes IORPs in FIDA’s scope if they manage personal pension products. This would generate disproportionate costs for IORPs that devote only a very minor part of their activities to personal pension products. To tackle this issue and correctly capture the specificities of the different pension systems across the EU, we suggest treating IORPs as a unique institution and leaving the decision to consider what is pillar 2 and pillar 3 to the Member States.
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