Insurance Europe is pleased to comment on EIOPA’s consultation on “draft technical specifications QIS of EIOPA’s advice on the review of the IORP Directive”.
Insurance Europe welcomes the decision to conduct a QIS with a view to better assessing the proposed review of the IORP directive and, more specifically to test the proposed HBS approach and specific features related to occupational pension schemes. This is a necessary step in the IORP Directive review process. Therefore we agree with EIOPA’s general aim as expressed in the introductory part of the consultation paper: “EIOPA’s consultation paper on the technical specifications for the study aims at helping IORPs perform the necessary calculations in the event that a Holistic Balance Sheet (HBS) approach would be implemented as part of the revised IORP Directive. The purpose of the consultation is to assess the valuation and risk mitigating effects on the solvency capital requirements of the pension funds' adjustment and security mechanisms, such as conditional and discretionary benefits, reductions of benefits, sponsor support and pension protection schemes.“