The CEA has reiterated its belief that the review of the Institutions for Occupational Retirement Provision (IORP) Directive must be based on two key principles: that the same rules and capital requirements should apply to the same risks and that substance should take precedence over form.
It has submitted a detailed response to the second consultation by the European Insurance and Occupational Pensions Authority on its advice to the European Commission on the IORP review. The response stresses that the risk-based Solvency II principles should serve as the basis for applying “same risks, same rules, same capital” to all financial institutions offering occupational pension products, provided their specific characteristics are taken into account. It also makes clear that products should be regulated according to their risks, not the legal vehicle through which they are sold.