On 6 November 2014, Insurance Europe published a position paper on the proposed IORP Directive. While the broad objectives of the Directive are welcomed by Insurance Europe, the paper sets out detailed comments on many of its provisions. Interestingly, the paper comments that the Solvency II Directive does not make provision for reinsurers to provide cover directly to IORPs but that the Reinsurance Directive currently permits Member States to allow this. Insurance Europe states that clarification is needed in this regard to ensure that IORPs can continue to make use of reinsurance for the benefit of their members and beneficiaries.