Digital

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 as indicated in our position paper published in September 2023. We also indicate that there is a need to rely on existing pension tracking services (PTS).

However, because of the embeddedness of occupational pension entitlements in employment contracts, their restricted accessibility for members, and the “social nature” of IORPs, we are advocating to clearly distinguish IORPs and related occupational pension schemes from others financial entities by restricting FIDA scope to those “accessible for all interested consumer” as highlighted in our last statement published in April 2024. 

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.