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.
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- 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