Reporting requirements for all pension funds have been introduced by the European Insurance and Occupational Pensions Authority (EIOPA) and the European Central Bank (ECB).

The first reporting deadline for the EIOPA requirements was intended to be Q4 2019. However, the Pensions Authority recently confirmed that, due to technical issues, the collection and reporting of the data to the EIOPA had been deferred for a short time. This will not impact on the Pension Authority’s own reporting deadlines and it does not affect the ECB reporting requirement deadline which remains December 2019.

EIOPA

EIOPA is commissioned with monitoring and identifying trends, potential risks and vulnerabilities in the insurance and occupational pensions sectors across the EU.

EIOPA is governed by its board of supervisors, which brings together the relevant national authorities in the field of insurance and occupational pensions in each Member State. It is an independent advisory body to the European Commission, the European Parliament and the Council of the European Union.

Day-to-day supervision of occupational pensions is carried out at national level by the relevant competent authorities, i.e. for Ireland the appropriate authorities are the Central Bank of Ireland and the Pensions Authority. However, EIOPA may request submissions on occupational pensions from the competent state authorities at recurring intervals and in a specified format. EIOPA also has a broad range of tasks and powers which are set out in Article 8 of the Regulation.

EIOPA decision on reporting requirements

In April 2019 EIOPA published a decision on the submission of occupational pension information from the competent authorities at national level. In the decision, EIOPA has defined a framework on the provision of this information to allow it to effectively monitor and assess the European occupational pensions sector, with a focus on financial stability.

The object of this EIOPA decision is to facilitate a smooth and efficient reporting process which will allow EIOPA to assess market developments in the area as well as to undertake an in-depth economic analysis of the sector across the EU.

The focus of the information request relates to:

  • Balance sheet information: to allow EIOPA to assess the financial and solvency position of occupational pensions
  • Inputs and assumptions used for pension fund valuations: this information will allow EIOPA to produce comparable statistics across the entire sector with the aim of understanding market characteristics, and
  • Flow data: for the detection of trends in the sector.

ECB reporting regulation

Separately, the ECB has also introduced Regulation 2018/231 on statistical reporting for pension funds. The CBI notes that the aim of the ECB Regulation is to provide enhanced statistics that will better support the European System of Central Banks in contributing to the stability of the financial system.

The ECB Regulation requires all pension funds and their trustees to report data on assets, liabilities, and membership numbers on a quarterly and annual basis. As part of the data collection for pension funds the CBI will collect and transmit this information to the ECB.

The CBI has stated that the first reporting will be made during December 2019. The ECB Regulation also requires the CBI to maintain a list of pension funds for statistical purposes. The requirements are mandatory and apply to all pensions and their trustees.

Conclusion

The key points here are:

  • Pension trustees and employers should review the EIOPA published decision to ensure that they are in a position to provide the necessary information when it is ultimately requested. The Pensions Authority has stated that large schemes will be required to submit detailed information on assets, liabilities and membership on a quarterly and annual basis and that small scheme will be required to submit summary data annually.
  • For the CBI requirements, there are sample reporting templates and guidance on their completion available on its website. Trustees and employers should consider the information that will need to be obtained from scheme auditors and/or investment managers so that the required data may be collated and returned to the CBI.