On 20 November 2025, the European Commission adopted a Pensions Package under the Savings and Investments Union (SIU) Strategy, including legislative proposals to revise the IORP II Directive and the PEPP Regulation, alongside a Communication and a Recommendation on pension-related tools and policies.
SGI Europe’s position highlights the following key messages:
- Support for strengthening supplementary pensions: Supplementary pensions play a key role in ensuring adequate retirement income and supporting long-term investment in Europe.
- Preserve minimum harmonisation and national diversity: The IORP framework must continue to respect the diversity of national systems, closely linked to labour, social and tax law, and often embedded in collective bargaining.
- Avoid additional regulatory burden without added value: The proposed expansion of requirements in governance, reporting, stress testing and sustainability risks increasing costs and complexity without clear benefits.
- Ensure proportionality, especially for smaller institutions: New requirements must be proportionate and adapted to the size, nature and risk profile of IORPs.
- Reject Solvency II-type approaches: Insurance-based regulatory frameworks are not appropriate for occupational pensions and risk undermining long-term investment strategies.
- Respect collective bargaining autonomy: Occupational pensions are often shaped by social partners. EU legislation must fully respect collective bargaining outcomes.
- Maintain PEPP as a voluntary third-pillar product: PEPP should complement, not interfere with, established occupational pension systems.
- Ensure coherence with competitiveness and simplification objectives: The revision should align with the EU’s Better Regulation agenda and avoid duplication or unnecessary complexity.
