EFAMA welcomes EIOPA’s consultation and the opportunity to share our views on EIOPA’s recommendations to develop an EU single market for personal pensions.
EFAMA supports the conclusions of EIOPA’s impact assessment:
• The standardization of key elements of a PEPP - as proposed by EIOPA in its advice - with space to accommodate the specificities of Member States, is the best policy option.
• It would be difficult to achieve full standardization via harmonization because this would require bringing all national regulations on PPPs to one level.
• We believe harmonization of PPPs would not be feasible, due to different social frameworks and taxation rules between member states. Furthermore, a full harmonization of PPPs would restrict competition between different product types and reduce choice for consumers.
• We strongly agree that the development of a successful EU Single Market for Personal Pensions can be achieved by a 2nd regime that creates rules for a standardized PEPP that do not replace national rules but are instead an alternative to them.
• The PEPP should benefit from an EU passport in order to be offered across Europe, once authorized by a competent authority in one Member State. To benefit from the passport, the PEPP should indeed be seen as a product. This said, the client of a PEPP may need to open an account.
Against this background, we recommend giving priority to the creation of the PEPP through the use of a 2nd regime.
For this reason, our response to the current consultation will focus on the PEPP and on the elements that should be part of its legislative framework.