Fritz Janda, managing director of the Austrian Pensionskasse Association
“We are happy with most of the things in the draft directive, there is nothing that is especially difficult for the Austrian market – apart from some lump- sum issues.
“We don’t have any particular problem with the exemption of book reserves – it is not our issue we represent existing pension funds.
“There are, of course tax regulation and labour issues which will need to be resolved in Europe and it will be necessary to take care of this to get the right vehicle.”

Des Crowther of the Irish Association of Pension Funds (IAPF)
Says the IAPF is still discussing the implications of the directive in depth.
“ The main thing from the Irish perspective is that we think the directive will be fine as long as it doesn’t impact negatively on what we already have in place.
“Without looking closely at the document it is difficult to say whether this is the case or not.
“If there is something we can build on then I think we will be happy with this.”

Ray Martin, chairman of the benefits committee, UK National Association of Pension Funds (NAPF)
“We particularly welcome the acceptance by the Commission of the prudent person approach which has proved so beneficial in the UK.
“The policy outlined in the draft directive will mean that those pension funds in member states which currently have restrictions on the type of assets they can hold will have more freedom to invest in equities and take advantage of overseas investment opportunities.
“This will be good new for members, companies and the economies of members states.
“I hope that progress can be made in the crucial area of taxation without any further undue delay.
“The costs involved in multinational companies having to set up different schemes in each members state where they have an employee is an unnecessary burden on business. Allowing such companies to set up a single scheme for all their European employees will result in greater efficiency and lower costs for employees and members.”

Martin van t Zet, public affairs spokesperson for the VB (Verening van Bedrijfspensioenfondsen) body for industry-wide pension schemes in the Netherlands
“We welcome the directive but also feel that the real discussions on Europe-wide pension progress have yet to come.
“We applaud the necessity for a draft directive as a first step towards Europe-wide fiscal treatment of pension and labour laws.
“One dilemma we have though is that although we know that the commission is not allowed to say anything about national pension provision, we find it strange that provision in countries based on PAYG or book reserves is not covered by the directive, yet countries with good pension provision on a capitalised basis are covered.
“Dutch regulations will not be affected because for the most part we fall within the directive framework.
“It may be that we have to implement some extra reporting elements to scheme members under some of the information obligations of the report, but we see this as a positive thing.
“We see the draft directive as a compromise between southern and northern countries, but our main question mark over it is whether there is anything which will make the European scene better.
“Are countries such as Germany going to have more capitalised pension provision on the back of this directive? Yes, it gives the possibilities to do so, but will they be taken?
“Also, the directive offers freedom investment but then goes and offers the possibility of investment restrictions to countries like France and Austria to set their own levels.
“We know where the real problems are, but the directive cannot touch them. We would like to see the Commission say that capitalised funding is the best system or that more balanced is needed with the first pillar.”

Georg Hagstrom, general secretary of the Swedish Association of Insurers and Pension Funds
“Article 3 on the separation of the entities which manage second pillar pensions will be difficult for insurance companies in Sweden – many of which have their second and third pillar business lumped together.
“SPP and AMF, for example, now have quite a bit of third pillar business and conversely Trygg Hansa and Skandia will also have problems because have quite large second pillar businesses. Now they will have to create different legal entities with different management etc, whereas until now they could carry out the management together.
“We are discussing this at the moment and then we will have to talk with the Swedish government about it. I suppose that this idea has come from the Germans. From a Swedish point of view the directive will not have that much impact. There will be some effect on open mutual pensionskassen for journalists etc – they will be slightly better off in freedom of investment.
“We don’t mind the directive very much in Sweden – the book reserve issue will not be touched and this is a big industry in Sweden.
“They have taken away a lot of the difficult details from earlier drafts, but it is a step in the long run for more cross-border affiliation, certainly. But taxation will be key.”

Vincent Vandier, head of AFPEN, the French Pension Fund Association
“There have been substantial changes to the draft of last year – article 12 in particular.
“It was agreed in the draft that pension fund solvency would be as least as tough as in the insurance guarantee – and it seems that the criteria is the directive for life insurance.
“There is also a lack of clarity regarding the creation of ‘own’ funds – is this paid in capital as in the life directive? I think there is some confusion here. I am also surprised at the number of exceptions, for example in Germany the book reserve and Unterstutzungskassen systems.
“I would say that we cannot change the world in one day, but if the new directive would be valid for new schemes in Germany then that would be OK.
“There are no real problems for the French system – there is a clear dividing line between the first pillar and funded schemes – and we are favourable with the outsourcing of pension funds and the dedicated structure. Most of the pension funds in France would meet the criteria. My overall impression is favourable.”

A spokesperson for the OPF body for company schemes in the Netherlands
“We already have investment freedom in Holland but the problem we feel with the directive is that the qualitative limits don’t go far enough.
“We would like to see the market open to prudential principles because we have seen over the years that it works well for our pension funds.”
“Other member states may want more substantial levels imposed on pension funds – so there is a balance to be met. It doesn’t hurt us but it doesn’t help us either – particularly when you look at the cross-border situation.
“Assuming you don’t even have a tax problem there will still be problems for multinational companies – facing the restrictions that we don’t think make much sense.”
“Another negative element is the minimum funding requirements (MFR) principles in the directive.
“We don’t think these rules really help because they don’t recognise the dynamic nature of pension funds. On a day-to-day basis or year-to-year basis the way to take decisions is through funding.”

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