PensionsEurope supports the objectives of SRD II to promote long-term shareholder engagement and strengthen corporate governance, while stressing that the framework must properly reflect the diversity of pension fund investment models across Europe.
In particular, the responses underline the distinction between direct and indirect investment structures and call for an appropriate framework for pension funds as long-term investors.
PensionsEurope also emphasises that the current “comply or explain” approach under Articles 3g and 3h should be maintained, without introducing additional disclosure obligations or mandatory engagement requirements that could create unnecessary administrative burden without improving engagement outcomes.
