The EU Savings and Investment Union from Policyholder Perspective

Enlarged Statement by Dr. Christian Gülich (IRSG member) at EIOPA Joint Meeting on 16 December 2025

Key Takeaways at a Glance

• Effective supervision and tailored advice are essential for life insurance products to safely support the Savings and Investment Union.

• Comprehensive Pension Tracking Systems across all pillars are essential for transparency and informed retirement planning.

• Voluntary auto-enrolment with opt-out options, mandatory employer contributions and targeted incentives can broaden occupational pension coverage.

• PEPP reform should increase flexibility while ensuring value for money through effective supervision rather than rigid cost caps.

• Strong product governance and advice quality are crucial to protecting policyholders across all initiatives.

Contents

Introduction

1. Connecting savings with productive investments

2. Pension Tracking Systems

3. Auto-enrolment for occupational pensions

4. PEPP Review

Conclusion

Introduction

Thank you very much for the possibility to give a statement on this crucial topic. As the leader of the IRSG working group on the consultation on “Supplementary Pensions” this summer, I will refer to this common document as much as possible, especially related to Pension Tracking Systems, auto-enrolment and the PEPP review. At the same time, I would like to add some observations, which are directly linked to the over-arching topic of the Savings and Investment Union, which we shall discuss during this session.

1. Connecting savings with productive investments

As it is well known, one of the main objectives of the Savings and Investment Union is to strengthen the investments of retail investors and savers in the European real economy. In this context, some product innovations by life-insurers can play an important role. I particularly refer to the product category of life insurances which are not just usual unit-linked products, but invest the saving part of the premiums into alternative investments like private equity, private debt, real estate, infrastructure projects or renewable energies. These investments can be made either directly or within the legal framework of an ELTIF. Sometimes a part of the technical reserves of the life-insurer “mirror”, so to say, the performances of the selected alternative investments.

It can be observed that the barriers for prospective policyholders have strongly been reduced after the review of the ELTIF directive last year: one of the first offers before this review had still asked for a lump sum of at least 25.000 Euro, now it has been reduced to 10.000 Euro. Other providers offer the possibility for additional lump sums at a later date, some set a minimum of 250 Euro. Still other offers ask for 5000 Euro as minimum lump sum. But not only lump sums are possible, some life-insurers offer contracts based on regular premium payments of at least 50 Euro per month.

So, on the one hand you can say that life-insurers have made considerable efforts in order to strengthen retail investments even by policyholders which are aligned with the general objectives of the Savings and Investment Union. On the other hand when giving advice on such an IBIP, an insurance intermediary must not only be able to explain included biometric risks like longevity or death, but also the functioning of the included alternative investments for instance related to liquidity risks.

So, I simply ask: Is the suitability test really granular enough, in order to find out the relevant customer target market and the necessary level of financial literacy? A much higher and detailed level of advice is obviously necessary, which is therefore more costly, but can the value for money still be maintained? Therefore, as far as I can see, there is a strong need not for more regulation, but for enhanced POG supervision by the competent authorities related to these product innovations.

2. Pension Tracking Systems

In our IRSG working group related to the PTS, a broad consensus on the minimum requirements could be achieved rather quickly. PTS should be extended beyond the 1st pillar to include the 2nd and 3rd pillars in a longer term. They should be available in both physical and digital formats, offering clear projections, interactive simulators, as well as net nominal and real returns and indicators of costs and risks. Mandatory participation by financial institutions and relevant stakeholders is essential to ensure completeness.

Related to the long-term inclusion of third pillar pension plans, I would like to add that in the German PTS, the DRÜ, even pension plans purely based on mutual funds can be included under the condition that the draw down plans do not start before the age of 60 of the prospective beneficiary. So, there is no obligatory annuitisation of the payouts.

3. Auto-enrolment for occupational pensions

In contrast to the previous point, on auto-enrolment there were strong discussions between and within the different sub-stakeholder groups:

• Product providers discussed for example the pros and contras of an obligatory default pension plan.

• For the future beneficiaries a possible lack of individual autonomy was discussed, if there is no opt-out option.

• Collective bargaining should not be a mandatory requirement, as this would create obstacles for employers without access to social partners and in consequence limit the spread of the occupational pension plans.

Nevertheless, as far as I understood, we could agree on some minimum requirements for auto-enrolment as the following:

• It is up to the public authorities to set legal framework for a voluntary, not a mandatory auto-enrolment system.

• Public authorities should create additional incentives for the targeted employees like tax benefits or subsidies, especially among low and middle-class earners.

• Contributions by the employers should be mandatory.

4. PEPP Review

The proposed changes by the Commission for Basic PEPPs include the introduction of a simplified lifecycle path, the removal of mandatory capital guarantees and of the mandatory second sub-account, as well as the requirement to make the Basic PEPP suitable for sales with reduced or even without investment advice.

Nevertheless, investment advice on PEPP must be made available but only if it is provided on an independent basis and at the investor’s request.

To give providers more flexibility, it is proposed to remove the current obligation that Basic PEPP and tailored PEPPs must be offered by the same provider.

Overall, I think that it is not exaggerated to say that these proposals are rather near to what we had discussed in our working group as possible compromise.

Related to the possible softening or even abolishment of 1% cost cap of the Basic PEPP, it was - of course - very difficult to develop a minimum consensus on this question. Therefore, the divergent positions of the different sub-stakeholder groups were fully outlined in the common paper.

But eventually we could agree upon some proposals how the value for money should be safeguarded, if the cost cap was abolished:

• A dynamic approach could be considered, for example a sliding scale where administrative costs decrease after certain holding periods.

• Additionally it could be stipulated that if a product provider exceeds the two percent threshold of costs (aligned to the long-term inflation rate goal by the ECB), an “enhanced supervision” by EIOPA should be implemented.

Some of you may know that right now in Germany there is an intensive public debate on pensions reform linked to several draft legislations. Therefore, the Council of Economic Experts who gives directly advice to the Federal Government recently published a concept of an individual retirement account, which includes some proposals, which are rather similar to the PEPP proposals by the COM:

• Standardized simplified products based on ETFs and life-cycle model;

• Advanced investors may choose UCITs and ELTIFs;

• Pure online distribution without advice for simplified products.

• Flexible payout options including draw down plans.

• Possibility of transfer for existing private and occupational pension plans to this new retirement account.

Of course, we will follow very closely, what will be the outcomes of these legislative procedures.

Conclusion

My conclusion simply is that leading this working group was a deeply inspiring experience. Despite of opposite opinions at the start we were able to elaborate a compromise on most questions. So again, I would like to thank you for this and now for listening.

Weblinks for background information:

IRSG response to COM consultation document: Targeted consultation on supplementary pensions – 4 September 2025

EIOPA provides its technical input to support the development of supplementary pensions in the context of the Savings and Investments Union – 8 September 2025

European Commission: Questions and answers on the supplementary pensions package - 20 November 2025

Better Finance: Mind the Pension Gap: EU Stakeholders Call for More Adequate and Inclusive Supplementary Pensions, Press Release – 03 December 2025

Eltif, AIF & Co. in Fondspolicen: So investieren Versicherer in Private Markets, in: Das Investment, November 2025

Sachverständigenrat Wirtschaft: Neustart der privaten Altersvorsorge in Deutschland: Ein renditestarkes Vorsorgedepot nach schwedischem Vorbild, Pressemitteilung vom 28. November 2025

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