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This position paper from Insurance Europe outlines their response to the European Commission's consultation on supplementary pensions, specifically addressing pension tracking systems, pension dashboards, auto-enrolment, and a review of the Pan-European Personal Pension Product (PEPP) Regulation and the Institutions for Occupational Retirement Provision (IORP II) Directive. The document emphasizes the importance of national diversity in pension systems, advocating against "one-size-fits-all" EU-level measures. It provides feedback on the effectiveness and challenges of existing frameworks, offering suggestions for improvement while consistently highlighting the need for flexibility, proportionality, and respect for national specificities in any proposed reforms. The paper also discusses the limited uptake of PEPP due to its complex and restrictive design, and offers insights into optimizing IORP II for long-term investment and member protection.

"We mathematically demonstrate how and what it means for two collective pension funds to mutually insure one another against systematic longevity risk. The key equation that facilitates the exchange of insurance is a market clearing condition. This enables an insurance market to be established even if the two funds face the same mortality risk, so long as they have different risk preferences. Provided the preferences of the two funds are not too dissimilar, insurance provides little benefit, implying the base scheme is effectively optimal. When preferences vary significantly, insurance can be beneficial."