European Policy Analysis Volume 2, Number 1, Spring 2016 | Page 57

European Policy Analysis

In the course of answering the
extensive catalogue of 71 questions, a
number of stakeholders seem to have
become a little annoyed with EIOPA.
Question 17, for example (“How could
a single market be developed for PPPs
unregulated at EU level?”; EIOPA 2013,17)
drew passes, back references, repetitions—
and several ill-tempered one-sentence
statements like the following two: “The
question wrongly presumes that there
are unregulated PPPs” (EIOPA 2014a,
com. 383), and “A single market for
unregulated PPPs should not be created”
(EIOPA 2014a, com. 395). To a certain
degree, EIOPA invited this sentiment with
redundancies and a cloudy consultantstyle32 as in question 39 that asks “What
regulation can be a source of inspiration
for personal pensions?” (EIOPA 2013).33
The ill will sparked by question 18 about
the feasibility of a “passporting regime
for providers of 1st pillar PPPs” (ibid.,
17), though, does not concern style, but
sensitive core areas of national interest.
The vivid comment from the Bulgarian
Association of Supplementary Pension
Security Companies not only lets us glimpse
the intensity of emotions involved, but also
demonstrates that advocacy coalitions can
have a strong regional dimension (as more
generally analyzed by Ebbinghaus 2015) to
them:

diverting 1st pillar contributions)
would mean for CEEC pension
providers to have passports but
not 1st pillar bis realm in Western
Europe to identify themselves
with. The relevance of such a 1st
pillar bis passporting with regard
to western Europe pension money
looks like the relevance of a sailingboat permission with regard to one’s
journey in Sahara. So cross-border
management of 1st pillar bis schemes
means that western EU managers
of pension money would be able to
manage directly an additional, easily
accumulated pension capital from
CEEC (without having the analogous
access to such 1st pillar assets in their
home countries), whereas their CEE
counterparties would not have such a
1st pillar bis pot of money in western
Europe to compete for. Put it briefly,
cross-border management of 1st
pillar bis pension money will drain
the scarce pension resources of CEEC
for the benefit of Western Europe.
(EIOPA 2014a, com. 400)34

Central Eastern European voices
are not alone in such resistance, however.
Scandinavian stakeholders like the
Finnish Pension Alliance point out that
there would be absolutely no basis in the
European treaties for such an initiative:
In the lack of 1st pillar bis type of “No, setting up a passporting regime for
retirement provision in Western providers of 1st pillar bis is not feasible by
Europe (established on the basis of any means. This idea is in direct violation

32

Sometimes, moreover, the written English is simply spectacularly bad: “Do you see the need of the
creation of a single market for products 1st pillar bis” (EIOPA 2013).
33
Those few stakeholders that bothered to answer this question listed a number of acronyms which
stand for other areas of EU regulation.
34
The Czech Ministry of Finance in com. 408 is less affective, yet equally opposed.
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