One of the key pensions-related actions in the European Commission’s flagship Capital Markets Union programme is the creation of an EU-wide framework for personal pensions.
EIOPA has been working for some while on the concept of an optional EU-level regulatory regime for EU-wide personal pension plans – the ‘Pan-European Personal Pension’ or ‘PEPP’.
The European Commission recently consulted on a wider range of options, including some less ambitious approaches such as sharing best practice between Member States.
The points made by the association in the current debate (and in response to previous rounds of consultation) have included the following:
- Introduction of the PEPP must not compromise or complicate the already relatively complex arrangements for regulating GPPs, with oversight shared between the Pensions Regulator and the Financial Conduct Authority. The creation of a further tier of regulation, through the development of a ‘28th’ or ‘2nd’ regime at EU level, could exacerbate the current difficulties.
- It is not clear that there is demand for the PEPP, nor is there a compelling case that it would work in practice.
- Tax barriers, in particular, pose a major barrier to the development of single cross-border pension schemes, and this remains a national competence and outside the scope of EU policy-making. It is not clear how EIOPA’s proposed approach to taxation of PEPPs – allowing them to receive the same beneficial tax treatment as national PPPs - would work in practice, given the different tax regimes across Member States.
European Commission consultation on personal pensions (July 2016)
EIOPA consultation on creation of a standardised Pan-European Personal Pension Product (July 2015)
EIOPA discussion paper - single market for personal pension (May 2013)