The Commission’s proposal to revise the activities and supervision of Institutions for Occupational Retirement Provision (IORP) is overly burdensome for employers and with no real benefits for employees.

• IORPs are social institutions and need to be considered as such in the Directive
• Overregulating IORPs’ governance will result in excessive administrative burden and undermine employees’ future pension provisions
• A comprehensive impact assessment should cover stakeholders’ and IORPs’ voluntary actions, not only existing legal requirements
• Administration and risk management measures should serve a purpose, not exist for their own sake
• Information obligations must be cost effective and proportionate to members’ and beneficiaries’ needs