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eIDAS                                                                                                                             Pan-European Personal


                                                                                                                                     Pension Products (PEPP)









                         Background            In the spring of 2018, the European Commission launched a pilot project             Regulation on PEPP                                                Background
                                               to make eIDAS better known and to enhance the uptake of the eIDAS tools
                                               by SMEs, amongst others focusing on SMEs in the financial services sector.          After the European Parliament and the Council of the EU had proposed
              The eIDAS Regulation has applied                                                                                     several amendments to the Commission’s proposal for Regulation  on   In June 2017, the European
             since 2016 and creates a European   BIPAR participated in a number of events organised by the Commission              PEPP, the three European legislators agreed on the text in trilogue in early   Commission published a proposal
                                               and shared the information packs and tools with its members (practical              2019. The text was published in the Official Journal of the EU in July 2019.
                internal market for the so-called                                                                                                                                                    for Regulation on a Pan-European
                                               guides, checklists, interactive tools, …).
              “eTrust Services” by ensuring that                                                                                   BIPAR and its member associations have been very active on this file all   Personal Pension Product (PEPP).
                these Services will work across   This also included a specific 1-hour Commission webinar in October 2018          along the legislative process.                                    It was adopted and published early
                                               on the possible use of the eIDAS systems and services by SMEs in the finan-
          borders and have the same legal status                                                                                                                                                     2019. Work on level II is now on
                                               cial services sector.  The webinar aimed to demonstrate the benefits of             Some key features of PEPP:
           as traditional paper-based processes.                                                                                                                                                     its way. The Regulation will apply
                                               introducing eIDAS solutions into daily business in the financial services sec-
                                               tor, focusing on:                                                                   -       PEPP is available to individuals with their residence in one of the   (directly) 12 months after publication
          These eTrust services are e-signatures,   -   Specific applications,                                                     EU Member States, irrespective of their nationality.              of the level II. The Regulation deals
                                               -      Benefits for SMEs in the financial sector: productivity gains, cus-          -       PEPP can only be provided and distributed in the Union where
              electronic seals (i.e. the electronic                                                                                                                                                  with the registration, manufacturing,
                                               tomer experience,                                                                   national authorities decide that they can be registered. This is done in a
           equivalent of a seal or stamp which is   -   Practical examples of implementation.                                      central public register, kept by EIOPA                            distribution and supervision of PEPP.

            applied on a document to guarantee                                                                                     -       PEPP can be provided by credit institutions,  insurers (engaged   PEPP is intended as an optional, 2nd
                                               The pilot project was concluded at the end of 2018 but the material remains         in direct life insurance), IORPs under certain conditions, investment firms
              its origin and integrity), electronic                                                                                                                                                  regime instrument, complementary
                                               accessible on the Commission’s website.                                             providing portfolio management, investment companies or management
           Time Stamps (i.e. date and time on an                                                                                                                                                     to the existing state-based (pillar 1),
                                                                                                                                   companies and EU alternative investment fund managers.
             electronic document which proves   Next steps                                                                         Insurance  intermediaries  (under  IDD)  and  investment  firms  providing   occupational (pillar 2) and national

          that the document existed at a point-in-  The European Commission has to report (to the European Parliament and          advice (under MiFID II) can distribute PEPP                       personal pensions (pillar 3) and has
                                               the  Council)  on  the  application  of  the  eIDAS  Regulation  by  1  July  2020.   -     PEPP providers have to offer a “Basic PEPP”, which is a “simple
           time and that it has not changed since                                                                                                                                                    standardised key product features.
                                               The report will assess to what extent the eIDAS framework remains fit for           and affordable default investment option” and where costs and fees shall
            then), electronic registered delivery   purpose delivering the intended outcomes, results and impacts and may          not exceed 1 % of the accumulated capital per year. The Basic PEPP has to   The Commission described PEPP
          service (i.e. the equivalent in the digital   identify possible further actions to improve regulatory performance. The   provide capital protection (capital guarantee or other risk mitigation tech-  as “a new, additional opportunity
                                               Commission will conduct an evaluation in line with the Better Regulation            niques with the objective to ensure that savers recoup the capital invested).
           world for registered mail) and website                                                                                                                                                    to save for retirement: simple,
                                               guidelines, also involving a public and a targeted stakeholder consultation.        Providers may offer up to 6 investment options (including the Basic PEPP).
                authentication certificates (i.e. a                                                                                                                                                  transparent & portable”. The PEPP
                                                                                                                                   All investment options shall be designed on the basis of a guarantee or
                       trustmark for websites).                                                                                    risk-mitigation technique which shall ensure sufficient protection for PEPP   proposal was launched together with a
                                                                                                                                   savers.                                                           Recommendation on the tax treatment
                                                                                                                                   -       There will be a precontractual PEPP Key Information Document,
             The eIDAS Regulation ensures that                                                                                                                                                       of personal pension products,
                                                                                                                                   largely following the example of the PRIIPs KID. This PEPP KID will also con-
            people and businesses can use their                                                                                    tain a heading on costs, including the cost of distribution. The PEPP KID   including PEPP.  The initiatives are part
           own national electronic identification                                                                                  shall include a clear indication that the PEPP provider or PEPP distribu-  of the bigger framework of the Capital
                schemes (eIDs) to access public                                                                                    tor shall provide information detailing any cost of distribution that is not   Markets Union.
                                                                                                                                   already included in the costs specified, so as to enable the PEPP saver to
            services in other EU countries where
                                                                                                                                   understand the cumulative effect that those aggregate costs have on the
             eIDs are available (this happens on                                                                                   return of the investment. On top of the PEPP KID, there is a standardised
             the basis of mutual recognition; for                                                                                  PEPP Benefit Statement during the product lifetime.
                                                                                                                                   -       PEPP portability: this concerns the possibility of continuing to con-
           the private sector the legislation only
                                                                                                                                   tribute into an existing PEPP account when changing residence to another
             encourages Member States to open                                                                                      Member State. In case portability is not available, consumers can switch
             the use of eID to the private sector).                                                                                provider free of charge or can continue to contribute to the PEPP of the
                                                                                                                                   previous country. Within three years of the date of application of the Regu-
                                                                                                                                   lation, each PEPP provider shall offer national sub-accounts for at least two



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