Invest Europe

Position Paper on the Supplementary Pensions Package

Positions & consultation responses

13 Feb 2026

The Institutions for Occupational Retirement Provision (IORP) Directive review offers an opportunity: decoupling the concept of prudence to investments in specific types of assets or sectors - notably listed or daily-traded instruments.

Prudence should be seen holistically. IORP – and the national legislation implementing it in practice - should designed to invite pension funds to construct well-diversified portfolios which meet their long-term liabilities, not portfolios that are mostly made up of low value, short-term assets.

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