The Pan-European Personal Pension Providers Association (PEPPPA) welcomes the European Commissions proposal to revise the PEPP Regulation with the aim of improving its attractiveness, scalability and role within the Savings and Investments Union. Based on practical implementation experience, PEPP uptake has remained limited due to structural and operational barriers, and we therefore support the proposed reforms as an important step toward making PEPP a viable pan-European retirement solution. In particular, PEPPPA supports the introduction of employer contributions and auto-enrolment as key drivers of participation, especially for SMEs and individuals without access to occupational pensions, while emphasising the need to avoid fragmentation through clearer and more harmonised rules.
We also underline the importance of ensuring a true level playing field, including through consistent tax treatment and incentives across Member States, as well as addressing differences in VAT treatment between providers. Furthermore, simplification of the Basic PEPP, including the removal of mandatory advice, is strongly supported, although additional adjustments are needed to ensure fully streamlined onboarding and scalable distribution. PEPPPA also highlights the need for proportionate investment flexibility, improved transfer and portability rules, simplification of the sub-account structure, and the removal of distribution barriers resulting from divergent national interpretations. Overall, the review represents a timely opportunity to address the key limitations of the current framework and to ensure that PEPP can effectively contribute to increasing retirement savings and mobilising long-term capital across the European Union.
Our detailed comments can be found on the EU commission’s website using this link.