DORA entered into force on 16 January 2023 and will apply from 17 January 2025. It aims to establish a comprehensive framework for digital operational resilience in the financial services sector. We welcome the EU’s commitment to establishing a digital operational resilience in the financial service sector. We advocate for the specificities of IORPs and their services providers to be fully considered in the ESAs approach. The principle of proportionality should also be correctly reflected in level 2 measures to ensure a risk and principle-based approach.
PensionsEurope welcomes the Commission’s proposal for a framework for Financial Data access (FIDA) published in June 2023 which is a key component of the Commission’s digital finance strategy presented in September 2020. PensionsEurope recognises that there is a technology-driven trend towards greater use of data and data sharing in finance and beyond.
We want to emphasise that FIDA should build on existing pension tracking services (PTS), to allow European citizens to continue having a holistic overview of their pension benefits including public pension rights. Building on PTS would avoid undermining existing PTS and those currently being implemented, especially regarding information and governance requirements which would be unnecessarily costly for data holders.
We are also active on the Open Insurance workstream, which is led by EIOPA. While EIOPA indicated in its July 2023 consultation paper on an Open Insurance use case that it does not specifically address the Commission FIDA proposal, it also suggests that the feedback gathered could help future technical discussions. Here we want to highlight that 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 fund.