Germany’s Arbeitsgemeinschaft für betriebliche Altersversorgung (ABA) has called for the European Union’s minimum harmonisation approach to be preserved as negotiations on the revision of the IORP II Directive move forward.

The Council of the European Union agreed its negotiating position on the review in June 2026, paving the way for talks with the European Parliament once Parliament adopts its own position.

The review aims to strengthen transparency, risk management, and investment efficiency across institutions for occupational retirement provision (IORPs), while supporting the EU’s Savings and Investments Union agenda.

Speaking at ABA's Supervisory Law for IORPs conference in Bonn, the association argued that the revised framework needs to reflect differences between member states’ occupational pension, social security and labour law systems.

ABA head of the pension funds division, Jürgen Rings, stressed that retaining and strengthening minimum harmonisation was particularly important given those national differences.

“The delegated acts and EIOPA guidelines proposed by the European Commission are not suitable for occupational pension schemes,” he said.

“The ABA therefore rejects them outright.”

The association has previously warned that extending EU-level powers through delegated acts and European Insurance and Occupational Pensions Authority (EIOPA) guidelines could move the framework towards greater harmonisation and fail to reflect the particular structure of occupational pension provision in Germany and other member states.

The proposed internal stress test was another focus of the conference, with ABA deputy head of the Committee on Investment and Regulatory Affairs, Dr Stefan Nellshen, warning against applying a Solvency II-style methodology to German IORPs.

Responding to concerns around risk-based capital requirements, Nellshen said: “Nothing, if you calculate ‘correctly’ and determine the risks of IORPs using a methodology appropriate for German IORPs.

“However, this is not the case with the Solvency II methodology.”

ABA head of the expert committee on investment and regulation, Andreas Hilka, also argued that defined benefit (DB) schemes could achieve higher returns, but suggested that some of the measures proposed by the European Commission could hinder this objective.

He warned that the costs of additional requirements should remain proportionate to their benefits, arguing that some new requirements should be restricted to areas where occupational pension providers operate in open competition and beneficiaries can choose between investment options.

ABA added that the current proposals had not yet met the key objectives it believes should underpin the IORP II review, including creating an appropriate framework for IORPs, strengthening occupational pensions and supporting the Savings and Investments Union.

The association is therefore calling for the European Commission, together with affected member states, to carry out a comprehensive impact assessment of the proposed changes before trilogue negotiations begin.

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