Pensions experts across Europe have said that there is not a one size fits all approach for the implementation of auto-enrolment (AE) across Europe and it will take different solutions for different countries based on their systems.

This topic was discussed at length during a panel session at the PensionsEurope Annual Conference in Bucharest, last week, 10 April.

Against the backdrop of the European Commission’s newly launched Savings and Investments Union (SIU) initiative, which recommends greater use of AE in occupational pensions, panellists from several countries debated whether the model could be effectively applied in their own national systems.

Speaking on behalf of Germany, BASF head of pensions & other benefits, Beate Petry, expressed scepticism about AE’s suitability in the German context.

She argued that while AE has merits, it falls short in addressing the needs of low-income earners, who are often left behind in pension coverage and may not be the “best option” for the country.

Petry stressed that getting small and medium-sized enterprises (SMEs) “into the game” is essential for expanding pension participation.

“We need to think about how to reach those employers and employees who are currently not covered,” she said. “For Germany, a collective agreement model might work better for SMEs.”

Representing France, AFG director of employee savings and retirement, Grégory Miroux, took a more optimistic stance. He said AE could play an important role in “improving savings and increasing revenue in returns”.

“AE is a powerful means to channel savings. AE for workplace schemes could be a way to finance the future and to stimulate wealth through better and larger investments,” he added.

In Romania, the prospects for AE are promising but highly dependent on policy design, Association for Privately Administered Pensions in Romania (APAPR) board member and Carpathia Pensions CEO, Marius Ratiu, said.

Ratiu emphasised the newness of the Romanian system compared to other long-standing pension systems across Europe.

He said it must be “designed properly” and be “based on the right values” otherwise it risks being a “disaster” or having “no impact”.

He warned that Romania’s current pay-as-you-go system is unsustainable in the long term and “will not be able to support” savers.

Meanwhile, Stichting Pensioenfonds Medisch Specialisten CEO and PensionsEurope vice chairperson, Jacques Van Dijken, addressed the role AE could play in engaging self-employed workers in the Netherlands.

While acknowledging its potential benefits for this group, he was firm in his view that AE would not be compatible with the broader Dutch pension system.

“It could work for the self-employed,” Van Dijken said, “but overall, the Dutch pension framework doesn’t lend itself to AE.”

European Commission head of unit insurance and pensions, Tilman Lueder, also weighed in on the discussion. He clarified that the AE proposal within the SIU is not a binding mandate, but rather a policy recommendation aimed at addressing specific gaps in pension coverage.

“AE might be more effective in the catch-up phase, particularly for small companies that currently do not offer workplace or occupational pension schemes,” Lueder explained.

He suggested that such entities could benefit from pooling mechanisms to help manage costs and broaden participation.

In addition to this, Lueder announced at the conference earlier in the day that the European Commission plans to launch a consultation on the pension initiatives outlined in its SIU strategy in early May, in line with its intent to launch all pension-related initiatives in Q4 2025.

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