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:
- Universal auto-enrolment into 2nd or 3rd pillar pensions.
- Integrated EU pension dashboards with cross-border tracking.
- Stronger PEPP framework with lifecycle defaults & fair cost rules.
- Occupational PEPP option for workplace savings.
- 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.