European Policy Analysis Volume 2, Number 1, Spring 2016 | Page 47

European Policy Analysis

Commission themselves in this contest
will be discussed in the following section.
The result of this process will, to a large
extent, determine whether we shall see
a far-reaching policy change in the near
future or whether the change will remain
incremental.

underscore in their general comments
that consumers tend to approach the
sophisticated task of choosing a personal
pension product (PPP) guided by
enculturated risk preferences and mental
short cuts closely aligned to national
markets and associated with their
respective prevalent products (cf., e.g.,
EIOPA 2014a, gen. com. 13 and 14). Thus,
it is questioned whether more than just
a few customers would actually consider
buying a 2nd tier product (EIOPA 2014a,
gen. com. 1). Other stakeholders note that
economies of scale may not only—and not
the most efficiently—be realized by selling
PPPs directly to cross-border customers.
Alternatives mentioned (EIOPA 2014a,
gen. com. 14 and 18) are either tapping
into markets by buying or setting up
national subsidiaries or trying to attract
capital invested in nationally established
products on the secondary cross-border
investment market—a euro invested in a
pension fund usually does not stay there,
but is again invested by the fund elsewhere.
Yet, the latter practice, in turn, is one of
the sources of (too) high administrative
costs of existing PPPs that triggered the
Commission’s and EIOPA’s initiative in
the first place.

Before we delve into the
stakeholder comments themselves, some
statistics on participating stakeholders
are due. Two thirds of respondents to
the open call for advice are based in
member states, while a third operate on
the European level. Sector-wide, three
major blocks can be identified: overall,
28.5% represent the fund industry, 25%
represent the insurance industry, and 20%
work mainly in occupational pensions.
On the European level, the insurance
sector displays a stronger (and the
strongest) showing with 44%, pointing to

4. Findings

W

e have derived three analytical
topics (taxation, distributional
issues
between
different
providers, and the balance between the
three pillars) from our reading of the
political and regulatory contexts in Section
2. Regarding these topics, we engaged in a
critical qualitative content analysis of all
stakeholder statements in reply to EIOPA’s
call that are relevant to the topics under
investigation here, the findings from which
are being presented in Section 4.1. Section
4.2 is concerned with the position EIOPA
adopted vis-à-vis the Commission in the
process, in terms of both policy content
and defining EIOPA’s institutional role.
Our analysis is critical in the sense that we
focus upon questions from the call (listed
in Table 1) and respective answers with
far-reaching distributional implications
in Section 4.1. Furthermore, we critically
assess how depoliticizing the issues at
hand is normatively problematic in terms
of regulatory governance’s democratic
accountability.

A fourth topic that emerged
inductively from the Commission’s
call, the stakeholders’ responses, and
EIOPA’s position analyzed in Section
4.1, namely whether sufficient demand
for a standardized 2nd tier product is to
be expected at all, deserves a moment’s
attention in advance. Some stakeholders
47