PensionsEurope raises concerns over PEPP reporting requirements

PensionsEurope has raised some concerns over the proposed reporting requirements for the Pan-European Personal Pension Product (PEPP).

In a response to a consultation by the European Insurance and Occupational Pensions Authority (EIOPA), the association said that whilst understands the need for such stringent reporting requirements, the “always imply costs for pension providers”.

In particular, it highlighted that the reporting obligations and templates under consultation seem in line with the current reporting obligations of some potentially-eligible PEPP providers in certain member states, and much less with others.

“In our opinion, the PEPP reporting requirements should be as close as possible to current supervisory reporting used for national personal pension products and occupational pension schemes to avoid useless additional workload and related costs for savers. In this perspective, the supervisory reporting should be sufficiently broad and granular to cover those data that must already be reported at the national level for personal pension products,” it stated.

PensionsEuorpe does not believe that the consultation paper has sufficiently analysed and detailed the impacts that the new reporting standards would have on the different eligible PEPP-providers.

“The PEPP Regulation requires that the reporting requirements reflect the nature, scale and complexity of the business of the PEPP provider concerned, and in particular the risks inherent in that business. This implies that EIOPA’s analysis should consider the differences between providers, investigating the current highly divergent national approaches to product supervision, and providing more details on the (different) administrative efforts and costs needed to comply with these standards.

“The European Commission, in the Impact Assessment accompanying the PEPP Regulation, recognized that the administrative burden would depend on the supervision of PEPP providers at national level, as the PEPP is a new product category added to the existing portfolio of products provided by pension funds, insurers, investment firms, asset managers and banks, all subject to regulatory oversight by national competent authorities under existing regulatory frameworks,” it stated.

In addition, PensionsEurope highlighted that the reporting of national personal pension products is not subject to harmonized EU rules, so the efforts needed to adapt national reporting standards to these rules will be considerably different from one country to the other.

“In certain countries, the reporting requirements set in the template are very different from the current national requirements, thus leading to additional reporting requirements and information flows for pension funds. EIOPA should also consider the potential consequent impacts on the PEPPs market uptake, as certain providers might have much higher costs than others and would therefore not enter the market because of the high costs implied by the adaptation of overlapping reporting obligations among PEPP and local products through which providers may instrument PEPPs.”

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