Professional Documents
Culture Documents
The Dutch pension funds welcome the recently published Green Paper on Pensions. We
appreciate a holistic approach on pensions and the close co‐operation between the General
Directorates Internal Market, Economic and Financial Affairs and Social Affairs, Employment
and Equal Opportunities. Pensions are part of all the issues dealt with by the three directorates.
We think that the mentioned key challenges such as demographic ageing, changes in pension
systems and the impact of the economic and financial crisis need to be discussed at European
level, and that national policies on pensions need to be supported whilst respecting the
principle of subsidiarity.
The Dutch pension fund organisations, OPF and VB, subscribe to the main overarching
objectives of sustainability and adequacy of pensions, as mentioned in the Green Paper.
After a first assessment of the Green Paper, the Dutch pension fund organisations state the
following:
We agree that there is a need to balance time spent in work and in retirement, whereas more
flexibility is necessary. At the same time the employees need to have enough time to adapt to
the situation.
Strengthening the internal market for pensions is considered to be more critical, since pensions
are no market products, but part of the retirement income of pensioners. Therefore, pure
internal market rules cannot be applied to pensions. Equilibrium needs to be found between
social and internal market policy in this respect.
With regard to mobility and portability of pension rights, a proper assessment of the existing
technical challenges and the differences in local occupational pension system needs to be
made. We subscribe to the idea that pension rights should not be lost due to mobility.
Raising awareness on pensions as well as better informing participants about their future
pensions are important issues. Adequate and understandable information is necessary, but
needs to be clear and comprehensive.
The Dutch pension fund organisations call for a proper qualitative and quantitative impact
study when revising the IORP Directive. This is in particular important for reflections at
European level on a proper framework for technical provisions and insolvency protection.