The European Chemical Employers Group (ECEG), Ceemet – European Tech & Industry Employers, and industriAll Europe today published a common position warning that the wrong regulatory approach could weaken one of Europe's most reliable sources of retirement income.

Occupational pension funds operating in the EU are regulated by the IORP Directive. In November 2025,the European Commission published a proposal to review this Regulation. Pension systems consist of three pillars: the first pillar is the statutory pension that workers receive from the national pension administration; the second pillar is the supplementary pension that you can build via your employer; the third pillar is what an individual saves privately for their pension.

Occupational pensions (the second pillar) are collectively organised, employment-based arrangements, often governed by the social partners (employers and workers’ representatives) themselves. They are deeply embedded in national labour-law frameworks and systems of collective bargaining, and they already make a substantial contribution to long-term investment across the continent.

That is why both social partners insist that the revision of IORP II must preserve well-functioning national pension systems and strengthen the second pillar. It must not import regulatory approaches which put occupational pensions at risk under the pretext of, for example, an additional stress test. 

The social partners set out four clear conditions for the revision of IORP II. It should:

• preserve minimum harmonisation and national diversity, so Member States can respect their own pension traditions and industrial relations systems;
• avoid Solvency II-type requirements, and instead ensure stability, proportionality and simplification;
• strengthen occupational pensions as a reliable and attractive pillar of retirement provision; and
• safeguard statutory pensions and collectively negotiated occupational pension schemes.
• collectively negotiated occupational pension schemes.

The three signatories caution that proposals such as expanded EU-level stress tests and new solvency-related measures go beyond minimum harmonisation. In countries where defined benefit schemes remain common, these could trigger Solvency II-like effects, higher capital requirements and added funding pressure on employers, ultimately affecting the retirement security of workers. They also stress that collectively agreed schemes, which are negotiated between equal partners, should not be judged by the same yardstick as personal pension products sold in a provider-customer relationship.

"Only under these conditions can occupational pensions continue to contribute effectively to social security, long-term investment and the wider objectives of the European Union," the statement concludes.