EN    EN  
 EUROPEAN  
COMMISSION 
Brussels, 10.4.2014  
SWD(2014) 102  final/2 
  
CORRIGENDUM: Annule et remplace le document SWD(2014) 102 final du 27.3.2014. 
Concerne toutes les versions linguistiques; page 1, titre. 
COMMISSION STAFF WORKING DOCUMENT 
 
EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 
 
Accompanying the document 
Proposal for a Directive of the Europe an Parliament and of the Council  
on the activities and supervision of institut ions for occupational retirement provision 
 
(recast) 
 
(Text with EEA relevance) 
{COM(2014) 167 final} 
{SWD(2014) 103 final} {SWD(2014) 104 final} 
 
 
2 
  
1. INTRODUCTION  
Pension systems across the European  Union (EU) have to adapt in order to ensure adequate, safe 
and sustainable pensions. The Single Market, too, ca n contribute decisively to this goal. The White 
Paper on Pensions announces that “ [t]he Commission will, in 2012, present a legislative proposal to 
review [Directive 2003/41/EC on the activities a nd supervision of Institutions for Occupational 
Retirement Provision] ”. Institutions for Occupational Retire ment Provision (IORPs) are, like other 
financial institutions, an integral part of the Single Market.  
Directive 2003/41/EC marked a first step on the way to a Single Market. Ten years after its adoption 
the Directive needs to be revised for five reasons.  First, prudential barriers remain which make it 
more expensive for employers to join an IORP in other MSs. Second, the number of Europeans 
relying on defined-contribution (DC) schemes, which shifts risks from IORPs and employers to 
individuals, has increased significantly. Third, recent financial and economic crises have shown that 
current minimum levels of protection for scheme members and beneficiaries needs improving. Fourth, individuals do not receive essential inform ation in a comprehensible manner, which prevents 
them from making informed decisions about their re tirement financing. Fifth, supervisory powers 
are insufficient to ensure that IORPs comply wi th governance and transp arency requirements.  
Taking remedial action now to strengthening the EU’s micro-prudential regulation for IORPs is 
important since improving the performance of occupational pension funds requires long periods of 
time to materialise. Failing to act now would lead to  lost opportunities in terms of cost savings and 
investment returns, and inadequate financial pl anning by millions of European. It would also 
increase the burden disproportionately for the young generations and undermine inter-generational 
solidarity. 
This proposal does not consider the introduction of  new solvency rules for IO RPs. This decision was 
taken following the extensive concern expressed by stakeholders during public consultations and on 
the basis of the results of EIOPA’s Quantitative Impact Study (“QIS”) in July 2013. The Commission 
Services, with the support of EIOPA, will re-exa mine the issue once more complete data are 
available.  
2. PROBLEM DEFINITION  
The Commission has identified the following four main  issues: (1) complexity of  cross-border activity, 
(2) governance and risk management requirements; (3) communication with members; and (4) 
supervisory powers. 
2.1. Prudential barriers restricting the development of cross-border IORPs 
The experience of employers, IORPs and supervisors over the past years has clearly shown that 
important prudential barriers restricting cross-bord er operations of IORPs remain. First, there are 
additional prudential requirements for cross-border activity, notably the following: i. the Directive 
leaves the discretionary power to impose additional investment rules with the host supervisor in the 
 
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 case of IORPs operating across borders; and ii. on ly cross-border pension schemes must be fully 
funded at all times. 
Second, several definitions and procedures for cross-border activity are unclear, notably the 
following: i. no clear definition of cross-border  activity exists; ii. smooth transfers of pension 
schemes from one IORP to another located in a diff erent MS are not ensured; and iii. the scope of 
prudential regulation rules applicable in home MSs is uncertain.  
2.2. Governance and risk management requirements are not sufficiently 
comprehensive 
Direct failures of IORPs are rarely observed. IORPs do fail, however, indirectly and there are several 
indicators that these failures are caused by shor tcomings in the governance and risk management 
practices of IORPs. This gi ves rise to three issues: 
First, IORPs may not have appropriate governance func tions in place. This concerns in particular the 
internal audit and risk management functions, as  well as the actuarial functions for DB schemes. 
These functions' roles and activities are not sufficiently defined either. Consequently, these functions do not exist within IORPs or unqualified staff occupies key positions in the governance 
structure of IORPs. Moreover, a possible conflict of  interest could arise, as the functions may be 
shared by an IORP and its sponsor.   
Second, IORPs may not take a systematic approach to their own risk assessment and may not fully 
integrate the risk management system in the decision-making process of the IORP. A general lack of 
a comprehensive approach to risk management of financial institutions in the EU was revealed 
during the recent financial crises.  
Third, IORPs do not necessarily use a depository in  order to ensure the safety of their assets.  
2.3. Members do not receive easy to understand pension information  
Individuals need to be properly equipped to ta ke informed decisions about pension savings, but 
there are several strong indications of unsustainable  information inefficiencies, which lead to the 
conclusion that members and beneficiaries are not properly aware of developments that could negatively impact their pension benefits. Exampl es are reductions of accrued pension rights, 
significant costs and charges, lack of citizens' know ledge of their financial situation in general and in 
particular of the fact that they generally  do not save enough for their pension. 
2.4. There are shortcomings in the supervisory powers  
Effective prudential supervision requires adequate powers for national supervisory authorities to 
perform their function of monitoring the soundness of  IORPs. In the course of the consultations on 
this proposal three issues regarding supervisory powers have been identified. 
First, IORPs have the possibility to circumvent prud ential standards by chain outsourcing, i.e. 3rd 
party service providers transferring activities to subcontractors. Second, not all supervisory 
authorities have the power to develop necessary tool s to stress test the financ ial situation of IORPs. 
Third, supervisors could need additional powe rs in order to effectively supervise any new 
governance and transparency requirements introduced by this proposal. 
 
4 
 3. SUBSIDIARITY AND PROPORTIONALITY  
Although at present IORPs are important financing vehicles for retirement only in a few MSs, there is 
potential, looking forward, for further expansion in other MSs. MSs have been reducing, and some 
are still reducing, pension benefits from state pens ions. As a consequence, an adequate replacement 
rate for European citizens will require additional retirement income from occupational and personal 
retirement provision. In many MSs private pensions  are thus expected to provide for a larger share 
of retirement income over the next decades. Moreover, DC schemes are gaining importance and 
could increasingly be used in a cross-border cont ext since their product features are simpler as 
compared to DB schemes. 
Under Article 4 TFEU EU action for completing the internal market has to be appraised in the light of 
the subsidiarity principle set out in Article 5(3) TEU. EU level action can add value substantially because action by MSs alone will not: i. remove ob stacles to cross-border activities; ii. ensure a 
higher EU-wide minimum level of consumer protection ; iii. take into account positive externalities 
arising from scale economies, risk diversification a nd innovation inherent to cross-border activity; iv. 
avoid regulatory arbitrage between financial services sectors; v. avoid regulatory arbitrage between 
MSs; and vi. take into account in terests of cross-border workers. 
Under the proposed action, MSs retain full respon sibility for the organisation of their pension 
systems as well as for the decision on the role of ea ch of the three pillars of the retirement system in 
individual MSs. The revision does not call this prer ogative into question. Neither does the revision 
cover issues of national social and labo ur, fiscal or contract legislation.  
The proposal takes account of the principle of proportionality, as enshrined in Article 5(4) TEU, 
being adequate to reach the objectives and not going beyond what is necessary in doing so. The 
selected policy options seek to strike the right balance between public interest, protection of IORP 
members and beneficiaries, as well as the costs for IORPs, sponsors and supervisors. Although IORPs 
are not SMEs - many IORPs satisfy the criterion of staff headcount to be defined as SMEs but exceed 
the thresholds for annual turnover and/or annual balance sheet – it is important that regulation 
properly takes into account the nature of their activities and the fact that the scale and complexity of IORPs’ activities is generally less than that  of other financial institutions. The envisaged 
requirements have been carefully considered, craf ted as minimum standards and tailored to IORPs' 
specificities.  
The proposed action takes into account proportiona lity in each of the operational objectives in the 
following manner: i. governance functions have been limited to those that essential for IORPs; ii.  
documentation of own-risk assessment has been st reamlined to the specificities of IORPs; iii. 
mandatory appointment of a depository is limited  to DC schemes rather th an for all IORPs; iv. 
pension benefit statement is limited to maximum two pages, focuses on essential information and 
does not prevent IORPs from using additional types of disclosure following national requirements and their own communication style; v. new supervis ory powers are only granted to the extent that 
they are necessary to effectively supervise IORP s' activities; vi. supervisory reporting is not 
harmonised so as to respect different national  supervisory approaches; and vii. removal of 
prudential barriers for cross-border IORPs is limited  to those that have raised the most important 
problems for stakeholders.     
 
5 
 4. OBJECTIVES  
4.1. General objective 
The general objective of this initiative is to fa cilitate the development of occupational retirement 
savings. This is in line with the Commission’s 2012 White Paper " An Agenda for Adequate, Safe and 
Sustainable Pensions " in which it announced a set of 20 initiatives aimed at helping the MSs to 
better balance time spent in work and in re tirement and to develop complementary private 
retirement savings. The White Paper mentions that the review of the Directive would make 
occupational retirement provision more efficient a nd safer. This would make a decisive contribution 
to pension adequacy and sustainability. In its re solution of 21 May 2013, the European Parliament 
considers that this proposal should strengthe n prudential standards for governance and risk 
management and transparent information disclosures. 
4.2. Specific objectives 
An enhanced role of occupational retirement savings requires better access to supplementary 
schemes, including cross-border ones. This can be  facilitated if employers can effectively supply 
complementary private retirement savings and if pe ople trust pension schemes to deliver what they 
promise. Accordingly, this proposal – aiming to furt her facilitate cross-border activity and reinforcing 
safety by strengthening member protection – has four specific objectives: i. remove remaining 
prudential barriers for cross-border IORPs; ii. en sure good governance and risk management; iii. 
provide clear and relevant information to members a nd beneficiaries; and iv. ensure that supervisors 
have the necessary tools to fulfil their tasks.   
4.3. Operational objectives 
Eight operational objectives have been identified  to attain the specific objectives. Remaining 
prudential barriers can be removed by taking away the extra requirements for cross-border IORPs 
and by clarifying definitions and procedures for cross-border activity. Better governance can be 
achieved with three complementary and mutually re inforcing operational objectives: (i) ensure that 
IORPs are managed professionally; (ii) require do cumentation concerning risk management; and (iii) 
protect assets from operational risk. Informat ion to members can be made clearer and more 
effective by providing a simple statement with e ssential information about pension benefits on a 
yearly basis. Ensuring that supervisors have the ne cessary tools to effectively supervise IORPs can be 
achieved by granting them new powers in relation  to chain-outsourcing and stress testing and by 
making sure that supervisors have sufficient po wers to verify compliance with prudential and 
transparency requirements.     
Policy options 
4.4. Removal of additional requiremen ts for cross-border activity  
In considering the available policy options the appr opriate level and focus of further approximation 
of national laws should be assessed.  The options under consideration are: 
Option 1 – No policy change : different quantitative investment limits; more 
stringent rules for the funding ob ligation for cross-border IORPs. 
 
6 
 Option 2 – Remove additional requirem ents from the Directive :  no national 
quantitative investment limits; same conditions to restore full funding for cross-border and domestic IORPs. 
The table below summarises the analysis of the po licy options. Option 2 is the preferred option 
because effectively addressing the problem requires changes in the legal framework.  
Comparison of policy options against effectiveness, efficiency and coherence criteria  
Efficiency Coherence  Effectiveness 
Facilitate cross-border activity   
Option 1 0 0 0 
Option 2  ++ ++ ++ 
4.5. Clarifications of definitions and procedures for cross-border activity 
To attain this operationa l objective, the following options were considered:  
Option 1 – No policy change: maintains unclear definitions and procedures for 
cross-border activity (different interpreta tions of the definitions of cross-border 
activity, no provisions on cross-border tran sfers of pension schemes, lack of clarity 
about the scope of prudential and social and labour law rules).  
Option 2 – Guidelines or recommendations  for better enforcement and 
implementation of the Directive.    
Option 3 – Clarification of definitions and proce dures for cross-border activity in 
the Directive . 
The table below summarises the analysis of th e policy options. Option 3 is the preferred 
option because it effectively solves the problems identified by stakeholders and would contribute to economic benefits for employers willing to join an IORP abroad. 
 
Efficiency Coherence  Effectiveness 
Facilitate cross-border activity   
Option 1 0 0 0 
Option 2  0 -- 0 
Option 3  ++ ++ ++ 
 
4.6. Ensure that IORPs are managed professionally 
To attain this operationa l objective, the following options were considered:  
Option 1 - No policy change: one governance function (actuari al function) for DB and hybrid 
schemes and no functions for DC schemes. 
Option 2 – Add a risk management and an internal audit function: three governance functions for DB 
and hybrid schemes and two functions for DC schemes. 
 
7 
 The table below summarises the analysis of the po licy options. Option 2 is the preferred option 
because it improves the protection of member s and beneficiaries by taking into account the 
different sizes and nature of IORPs, while not unduly increasing the administrative burden for IORPs 
and sponsors.  
Comparison of policy options against effectiveness, efficiency and coherence criteria  
 Effectiveness Efficiency Coherence 
 More safety Facilitate cross-
border activity   
Option 1  0 0 0 0 
Option 2  ++ + + ++ 
4.7. Require documentation of risk management    
To attain this operationa l objective, the following options were considered:  
Option 1 – No policy change: IORPs do not carry out a systematic self-assessment 
of their risk profile and do not communica te that assessment to their supervisor. 
Option 2 – Introduce a Risk Evaluation for Pens ions report (REP) to document the 
IORP’s own risk assessment and as part of  that require qualitative descriptions of 
four key elements determining the funding position : (i) explicit valuation of margin 
for adverse deviation from best estimate as  a risk buffer in calculation of technical 
provisions; (ii) qualitative evaluation of sp onsor support accessible to IORP in case 
of funding shortfall; (iii) description of sa fety mechanisms available to IORPs in case 
of funding deficit, such as mixed benefits , discretionary benefits or ex-post benefit 
reductions; and (iv) qualitative evaluation of operational risks for all schemes. The 
REP is reported to the supervisor. 
Option 3 – Same as option 2 plus common reporting on national solvency rules:  
require DB and hybrid sche mes to report to supervis or in a common format the 
value of their assets and liabilities follo wing national requirements and require 
them to quantify, where applicable, secu rity- and benefit adjustment mechanisms. 
The table below summarises the analysis of the policy options. Options 2 and 3 would both improve 
the  governance of IORPs. But option 2 is the preferred option because it is expected to be more 
efficient for employers/IORPs as it: (i) it leaves sufficient flexibility for IORPs to describe their 
particular situation in a way that reflects the nature, scale and comple xity of their activities; and (ii) 
it is expected to be considerably less costly than option 3.  
Comparison of policy options against effectiveness, efficiency and coherence criteria  
 Effectiveness Efficiency Coherence 
 More safety Facilitate cross-
border activity   
Option 1   0 0 0 0 
Option 2  + + + + 
Option 3  ++ + - + 
 
8 
 4.8. Protect assets from operational risk  
To attain this operationa l objective, the following options were considered:  
Option 1 – No policy change: IORPs are not required to appoint a depository; no 
provisions on the safe-keeping and oversight of assets functions. 
Option 2 – Strengthen the safe-keeping and oversight of assets functions ; this 
means (i) financial instruments have to be subject to due care and protection; (ii) 
records have to be kept, to be able to id entify all assets at any time and without 
delay; (iii) all necessary measures need to be taken to avoid any conflicts of interest 
or incompatibility; (iv) depositories or trust ees need to carry out instructions of the 
IORP, unless they conflict with the applicable  national and/or EU regulations; (v) 
ensure that in transactions involving th e assets of IORPs any consideration is 
remitted to it within the usual time limits ; and (vi) ensure that income produced by 
assets is applied in accordance with all national and/or EU regulations. 
Option 3 – Strengthen the safe-keeping and ov ersight of assets functions and 
make the appointment of a deposi tory compulsory for all IORPs: same as option 2 
but appointment of a depository is compulsory.  
Option 4 – Strengthen the safe-keeping and ov ersight of assets functions and 
make the appointment of a depository  compulsory for pure DC schemes: same as 
option 3 but appointment of a depository  is compulsory for pure DC schemes. 
The table below summarises the analysis of the po licy options. Option 4 is the preferred option 
because it is expected to contribute to the gain for employees in terms of better governance in a 
proportionate manner by avoiding unnecessary duplica tion of protection against operational risk.  
Comparison of policy options against effectiveness, efficiency and coherence criteria  
 Effectiveness Efficiency Coherence 
 More safety Facilitate cross-
border activity   
Option 1 0 0 0 0 
Option 2  + 0 - 0 
Option 3 ++ 0 -- ++ 
Option 4  ++ 0 + ++ 
4.9. Make available an annual pension benefit statement 
To attain this operationa l objective, the following options were considered:  
Option 1 – No policy change : generic scheme information is provided in most cases 
on request; personal information is limited; no obligatory pre-enrolment 
information and no common template.     
Option 2 – Personalised information for all stages : generic and personal 
information is provided once a year; pr e-enrolment information, but no common 
template.    
 
9 
 Option 3 – Standardised annual Pension Benefi t Statement (PBS) for all stages : 
same as option 2 but with a common template. A short and standardised annual PBS would contain both personalised a nd generic information about the pension 
scheme. The PBS would be produced acco rding to a standard template of two 
pages to be fine-tuned by EI OPA in a delegated act. The PBS would be the first layer 
in a modern multi-layered approach to communication, which enables national specificities to be described in -depth in subsequent layers.  
The table below summarises the analysis of th e policy options. Option 3 is the preferred 
option because it would enable members and be neficiaries to have a personalised overview 
of their rights and entitlements.  
Comparison of policy options against effectiveness, efficiency and coherence criteria 
 Effectiveness Efficiency Coherence 
 Provide clear 
and relevant 
information  Facilitate 
cross-border 
activity   
Option 1 0 0 0 0 
Option 2 + - + + 
Option 3 ++ ++ + ++ 
4.10. Ensure supervision of chain outsourcing  and the possibility to require stress 
tests 
To attain this operationa l objective, the following options were considered:  
Option 1 – No policy change .  
Option 2 – Give supervisors the same powers vi s-à-vis subcontractors as vis-à-vis 
service providers and the possibility to require stress tests ; no harmonisation of 
supervisory reporting. 
The table below summarises the analysis of th e policy options. Option 2 is the preferred 
option because it would increase safety for members and benefi ciaries through better 
supervision of IORPs and supervisors would have  appropriate tools at their disposal to do 
their job. 
Comparison of policy options against effectiveness, efficiency and coherence criteria 
 Effectiveness Efficiency Coherence 
 More safety Facilitate cross-
border activity   
Option 1 0 0 0 0 
Option 2 ++ + ++ ++ 
4.11. Ensure supervision of requirements  on governance and transparency 
To attain this operationa l objective, the following options were considered:  
Option 1 – No policy change .  
 
10 
 Option 2 – Give supervisors the power to superv ise the proposed requirements on 
governance and transparency ; no harmonisation of supervisory reporting. 
The table below summarises the analysis of th e policy options. Option 2 is the preferred 
option because it would enable supervisors to supervise IORPs effectivel y, which is coherent 
with other financial sectors in the EU. 
Comparison of policy options against effectiveness, efficiency and coherence criteria 
 Effectiveness Efficiency Coherence 
 More safety Facilitate cross-
border activity   
Option 1 0 0 0 0 
Option 2 ++ + ++ ++ 
5. ANALYSIS OF MAIN IMPACTS OF THE PREFERRED POLICY OPTIONS  
Although the proposed action involves short-term adjustments costs, the benefit of the entire 
package of preferred options is expected to outweigh the costs in the medium to long term.  
5.1. Economic benefits 
For employees  
The proposal is expected to provide significant ec onomic benefits to employees. Better governance 
is likely to increase risk-adjusted investment retu rns which help to achiev e efficient outcomes in 
terms of retirement income or contributions. Be tter communication will help individuals make more 
informed decisions about their retirement financing.  Cross-border IORPs are likely to bring additional 
efficiency gains, scale effects for small workforces  and for mobile workers a 'one-stop-shop' could be 
created for their pension arrangement. 
For employers  
The proposed action is expected to benefit empl oyers and these might be even more pronounced 
for SMEs and multinationals: 
Companies operating on a small or local scale could save costs  by joining an existing IORP. Better 
governed and more efficient IORPs are expected to lessen a burden for their sponsor. Moreover, 
companies operating on a small or local scale where no deep and efficient IORP market exists could 
benefit from joining an existing IORP abroad rather than setting it up locally. Indeed, IORPs 
established in MSs with established pensions expe rtise might extend their service to sponsors in 
other MSs. The Commission Services are aware of re cent cases, where the social partners for SMEs 
operating in one MS had the intention of setting up an IORP in another MS, largely to due product unavailability in the local market.  
Many multinationals operate an international pa tchwork of local pension funds. This increases 
complexity, leading to less transparency, hidden risk s, inconsistencies and in efficiencies. Companies 
can avoid this by merging local pension funds into one IORP.  
 
11 
  
For SMEs  
IORPs are formally not SMEs because they generally  hold assets above the threshold. Many are, 
however, small financial institutions. Simplifying cr oss-border definitions and procedures is likely to 
benefit small IORPs even more than large IORPs beca use they have less financial capacity to absorb 
transaction costs. Sponsors that are SMEs, includi ng groups of SMEs, will benefit from having easier 
access to IORPs already established in markets abro ad, thereby avoiding much of the initial market 
entry cost and benefit from the law of large numbers. 
For supervisors  
The new regime is likely to require greater supervisory resources. However, the extent that this 
reflects a change in costs for supervisors depend s strongly on pre-existing national regimes, which 
may already have resources for targeting the quality of supervision of IORPs. 
For Member States’ budgets  
The proposed action is expected to have two posi tive impacts on MSs' budgets. First, well-governed 
IORPs and a deeper market for IORPs strengthen pri vate occupational retirement provision. This in 
turn contributes to alleviating the pressure on st atutory schemes. The MSs  that have the potential 
to benefit most are those where the IORP market is small in relation to the size of their economy. 
Second, well-informed individuals can be expected  to make better decisions about their pension 
savings when they are young. As such this proposal  is likely to lead to a situation in which better 
informed citizens exert less pressure on statutor y pension systems which is beneficial for fiscal 
sustainability.  
5.2. Social benefits 
The proposal is expected to have a significant positive social impact. First, the demand for any 
financial product is largely driven by trust an d performance. The proposed action will make 
occupational retirement products more efficient and safer. It is therefore likely to contribute to increasing the coverage rate of complementary private retirement savings, thereby strengthening 
social protection and income equality in a rapi dly aging society. Second, greater safety and 
awareness through more effective information disc losures will make the public better informed 
about the pensions gap. This incentivises individuals  to take informed decisions about the amount of 
savings needed for an adequate pension and the choice  of investments, in order to save efficiently. 
Third, the common format of the PBS is likely to support the functioning of the labour market for 
people who work in different MSs. Finally, more transparency will help social partners to subject the 
management of IORPs to greater discipline an d thereby potentially enhance risk-adjusted 
investment returns.     
5.3. Environmental benefits  
The proposed action is not expected to have any significant direct environmental impact.  
 
12 
 5.4. Costs 
The expected cost of the proposed action is an increase of the administrative burden mainly as a 
one-off adjustment cost in the sh ort-term, and somewhat higher recurrent costs in the new regime. 
An estimate of the IORP industry of the administ rative burden has pointed to three elements that 
were expected to be the most expensive. The prop osed action avoids the two most costly elements 
by taken into account proportionality in the se nse that IORPs are not required to report common 
quantitative funding elements in the REP and that th ey can reduce the governance functions to two. 
DC schemes in some MSs are expect ed to incur an additional cost from the appointment of a 
depository. 
5.5. Macro-economic impact 
The proposed action is not expected to have any significant direct macroeconomic impact, although 
three indirect benefits might be expected.  First, good governance and risk management of IORPs is expected to reinforce their role as long-term in vestors in the European economy by avoiding an 
excessive focus on risk-return profiles in the short-term. Second, better performing and safer 
retirement products are also expected to increase  staff motivation and impact labour productivity 
positively.  Third, more efficient occupational pensions, in terms of attaining a higher level of risk-
adjusted returns on assets, will contribute to support the purchasing power of the retired 
population.  
5.6. Impact on third countries 
The proposed action does not concern a policy fi eld in which international regulatory approaches 
exist. It is not expected to have any signi ficant direct impact on third countries.  
5.7. Overview of benefits and costs 
The benefits of the package of preferred options are mainly economic, as well as social given the 
importance of an adequate and sustainable retirement system in an aging economy.  
Although the proposed action involves short-term adjustments costs, the benefit of the entire 
package of preferred options is expected to outweigh the costs. The financial gains for the 
employees are expected to be significant. Employer s can expect to realise further scale economies 
and may pass-on at least some of the additional administrative burden to scheme members and beneficiaries. Overall the proposed action is likely to be value creating in an ageing economy. It can 
help attain a higher social outcome without undermining economic growth.  
6. MONITORING AND EVALUATION  
The Commission Services will prepare an Implemen tation Plan where the following actions will be 
considered: meetings with MSs, exchange of best  practices amongst all MSs, training programmes 
addressed to national authorities. A preliminary examination by EIOPA followed by an evaluation 
report by the Commission would also be considered and envisaged.  
The evaluation of effects of the preferred policy op tions shall be carried out to see to what extent 
the anticipated impacts materialise. Therefore, an  ex-post evaluation of the application of the 
revised Directive should take place five years after the adoption of the Directive. It shall take the 
 
13 
 form of a Commission report to the European Pa rliament, the Council, and the European Economic 
and Social Committee. It may be accompanied, if necessary and in the light of developments, by 
policy recommendations or proposals for amendmen ts to this Directive. EIOPA will collect the 
qualitative and quantitative data. The Occupational  Pensions Stakeholder Group of EIOPA will also 
be consulted and the Commission’s Financial Serv ices User Group could also be involved. A 
Eurobarometer survey and a loose survey with IO RPs, employers, members and beneficiaries will 
also be considered. Employers could be targeted  for questions concerning possible difficulties of 
setting up pension schemes abroad. Improved disclosures by IORPs, in terms of quantity (i.e. 
increased number of statements or reports) and quality of the information disclosed, would be 
indicators of better transparency. On governance, th e increase of specific requirements for functions 
would be assessed. For cross-border provisioning, the number of cross-border IORPs would be taken 
into account.