The impact of Solvency II rules

On 15 February 2012, the European Insurance and Occupational Pensions Authority (EIOPA) presented its response to the call for advice of the European Commission regarding the revision of the IORP Directive. An important part of this call for advice1 is dedicated to the question to which extent the Solvency II framework for insurance companies could be used to create a harmonised European ramework for the supervision of IORPs. The main instrument that EIOPA has proposed to achieve this latter objective is the ‘holistic balance sheet framework’. In this framework all security mechanisms within a particular pension scheme should be valued and taken into account. Although this framework theoretically offers the possibility to achieve the aims of the review, the applicability and complexity involved is still an issue of concern.

In a recent statement, Commissioner Michel Barnier of Internal Markets and Services clearly indicated that there is no intention to directly ‘copy-paste’ Solvency II rules2. This article offers support to this judgment by showing that applying Solvency II to Dutch IORPs results in a highly adverse impact for both the individual participant and the larger economy.