News

Our response to the European Commission’s consultation on Pensions.

16 Sep 2025

Introduction

Supplementary pensions are under review in Europe. With demographic pressures weighing on public pensions, the European Commission has launched a targeted consultation on supplementary pensions (2025) to explore ways of improving occupational and personal retirement provision.

At LifeGoals, we have actively engaged in this consultation. As both a cross-border IORP and one of Europe’s first PEPP providers, we see this as a pivotal opportunity to strengthen adequacy, portability, and trust in Europe’s pension systems.

We have submitted a detailed response to the consultation — available in full here — and provide a summary of our positions below.

The EU Consultation in Context

The Commission is exploring:

• Pension tracking and dashboards to give citizens a clear view of their entitlements.
• Auto-enrolment mechanisms to widen coverage.
• A review of the PEPP Regulation to improve uptake and functionality.
• A review of the IORP II Directive to enhance cross-border efficiency, supervision, and investment rules.

The consultation closed in August 2025; next steps will include analysis of stakeholder responses and potential recommendations or legislative changes.

Executive Summary of LifeGoals’ Response

As part of our submission, LifeGoals highlighted the following priorities:

1. Pension Tracking & Dashboards

• Integrated, objective tracking systems covering all three pillars.
• Cross-border interoperability for mobile workers.
• Dashboards should show forward-looking adequacy and sustainability projections.

2. Auto-Enrolment

• Universal coverage: all workers (employees & self-employed) should be enrolled in either 2nd pillar or PEPPs.
• Default plans should feature lifecycle strategies, scalability, and gradual contribution increases.
• Legislators should define neutral default structures.

3. PEPP Regulation Review

• Broad endorsement of the Basic PEPP as a transparent, portable, cost-effective solution.
• Support for built-in lifecycle strategies as the default.
• Execution-only distribution to reduce costs and encourage digital uptake.
• Maintain alternative options (e.g. ESG, employer-matching).
• Revise the 1% fee cap to exclude VAT and third-party costs.
• Open the PEPP to workplace use, creating a Pan-European occupational vehicle.

4. IORP II Directive Review

• Allow more flexible investments (including alternative assets).
• Improve cross-border portability and supervisory convergence.
• Enhance disclosure standards and integrate IORPs into tracking systems.

5. Guiding Principles

• Universal coverage through auto-enrolment.
• Portability and continuity for mobile workers.
• Transparency and comparability across products and Member States.
• Balanced regulation: protect consumers without stifling innovation.

LifeGoals’ Priorities at a Glance

👉 5 Things We’re Calling For:

1. Universal auto-enrolment into 2nd or 3rd pillar pensions.
2. Integrated EU pension dashboards with cross-border tracking.
3. Stronger PEPP framework with lifecycle defaults & fair cost rules.
4. Occupational PEPP option for workplace savings.
5. Smarter IORP rules enabling flexibility and long-term investment.

Conclusion

Europe stands at a turning point for supplementary pensions. By embracing transparency, innovation, and pan-European solutions, the EU can ensure stronger retirement outcomes for its citizens while channelling long-term capital into the economy.

LifeGoals is committed to contributing actively to this process — and we invite our stakeholders, partners, and peers to review our full response here.