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European Association of Paritarian Institutions of Social Protection

AEIP

The AEIP represents non-profit social protection institutions managed jointly by employers and unions.

Lobbying Activity

Response to Construction services Act

12 Dec 2025

The European Association of Paritarian Institutions represents non profit social protection bodies jointly governed by social partners across 13 European countries and supports EU initiatives that strengthen fair mobility, worker protection and effective enforcement while respecting national systems. In its position, AEIP welcomes efforts to reduce barriers in the Single Market but firmly opposes the creation of an EU wide construction site card and any centralised mechanism for paritarian contributions, arguing that these would undermine well functioning national enforcement tools, collective agreements and paritarian governance. Instead, AEIP advocates for digital interoperability between existing national social ID systems through a decentralised European data space that enables secure information exchange, supports labour inspectorates and facilitates cross border service provision without duplication or disruption. AEIP also stresses that issues such as double contributions are best addressed through targeted bilateral and multilateral cooperation between paritarian institutions rather than one size fits all EU solutions, calling on the Commission to prioritise transparency, subsidiarity and support for existing cooperation models that already protect workers rights while avoiding unnecessary administrative burdens for companies. You can find attached our full position paper.
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Meeting with Dirk Gotink (Member of the European Parliament)

8 Dec 2025 · Supplementary pensions package

Meeting with Sonia Vila Nunez (Cabinet of Executive Vice-President Roxana Mînzatu)

6 Nov 2025 · To exchange views on the supplementary pensions' package.

Meeting with Maria Luís Albuquerque (Commissioner) and

23 Oct 2025 · SIU, DORA and PEPP

AEIP supports worker cancer protections with flexibility for SMEs

21 Oct 2025
Topic — The European Commission is proposing stricter exposure limits for cancer-causing substances at work.
Message — The group supports new exposure limits but demands sector-specific guidance for construction worksites. They request gradual implementation and financial support to help small businesses adapt to the rules.123
Why — These proposals reduce the immediate financial burden on companies and leverage AEIP's training services.45
Impact — Workers face ongoing health risks while companies delay compliance during the proposed transitional periods.6
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Meeting with Larisa Dragomir (Cabinet of Commissioner Maria Luís Albuquerque)

2 Oct 2025 · Supplementary pensions

AEIP urges sustainable and inclusive EU housing strategy

17 Sept 2025
Topic — EU initiative to boost productivity and close the supply gap in housing construction.
Message — AEIP calls for a housing strategy prioritizing deep renovation and skills development. They advocate for streamlined qualification recognition and fair conditions for cross-border workers.12
Why — This secures the role of paritarian institutions in managing sectoral training and social protection funds.3
Impact — Real estate speculators face potential limits if densification policies restrict new tourist housing units.4
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AEIP Urges Recognition of Paritarian Funds in EU Social Plan

9 Sept 2025
Topic — The consultation gathers feedback on implementing the European Pillar of Social Rights via a new Action Plan.
Message — AEIP calls for formal recognition of paritarian institutions as key actors in delivering social rights. They advocate for expanded occupational pension coverage and a new EU initiative for vocational rehabilitation.12
Why — Formal recognition would solidify their influence and secure dedicated funding for social partner projects.34
Impact — Financial services firms might see reduced influence as policy shifts from market-driven models to social protection.5
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Meeting with Arash Saeidi (Member of the European Parliament, Shadow rapporteur)

8 Jul 2025 · Insolvency

AEIP seeks tailored sustainability disclosure rules for pension funds

30 May 2025
Topic — The EU is reviewing sustainable finance disclosure rules to simplify reporting and prevent greenwashing.
Message — AEIP advocates for the removal of Articles 8 and 9 to simplify sustainability information for pension members. They request an exemption from pre-contractual disclosures and the removal of burdensome product-level impact indicators.123
Why — This would reduce administrative complexity and lower compliance costs for pension institutions.45
Impact — Environmental watchdogs and regulators lose access to granular data on the negative impacts of investments.6
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Meeting with Johan Danielsson (Member of the European Parliament)

28 Apr 2025 · EU förslaget om ett gemensamt system för utstationeringsregister

Meeting with Andreas Schwab (Member of the European Parliament, Rapporteur)

16 Apr 2025 · eDeclaration on the posting of workers

Response to Savings and Investments Union

6 Mar 2025

The European Association of Paritarian Institutions (AEIP) has responded to the European Commissions call for evidence on the Savings and Investment Union emphasizing the critical role of paritarian occupational pensions in strengthening Europes savings and investment landscape. AEIP welcomes the initiatives objective of leveraging Europes private savings to support broader EU economic and social goals. To this end, AEIP urges the EU to focus on increasing coverage and strengthening paritarian occupational pensions. This can be achieved by reinforcing industrial relations and enhancing the role of social partners in shaping pension policies through collective agreements, which could lead to an increase in mandatory or quasi-mandatory occupational pension plans. Expanding occupational pensions would offer a more sustainable and equitable approach to securing Europeans' financial futures in retirement while upholding the European social model. Occupational pensions play an increasingly important role in securing financial stability for European citizens. The European Commission should encourage this positive trend by recognizing the unique nature of these pension schemes. Since they are deeply integrated within national labour and social security systems, EU policies must respect national competencies and the diversity of pension systems across Member States. Paritarian pension funds ensure good governance, foster transparency, and uphold compliance with the prudent person rule, while guaranteeing employer contributions. These principles are fundamental in strengthening trust and confidence in long-term financial planning. A well-functioning Capital Markets Union (CMU) can provide better access to diverse sources of capital across the EU, helping paritarian institutions to reduce costs, improve portfolio performance, and optimize risk management. This, in turn, leads to greater social protection benefits for fund members. In its response, AEIP underscores that EU policymakers must recognize the specificities of paritarian pension funds and foster a financial environment that attracts targeted investments within the EU single market. However, pension funds should not be pressured to prioritize EU competitiveness at the expense of their primary social missiondelivering adequate and sustainable pensions for European workers. AEIP remains committed to engaging in constructive dialogue with the European Commission to identify initiatives that attract more investments while safeguarding the long-term objectives of pension funds and ensuring good pension outcomes for members and beneficiaries.
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Meeting with Michalis Hadjipantela (Member of the European Parliament)

26 Feb 2025 · Introductory Meeting

Paritarian group AEIP seeks exemptions from financial market rules

31 Jan 2025
Topic — A consultation on modernizing the EU single market for services and goods.
Message — AEIP wants the EU to recognize the distinctions between paritarian institutions and financial market entities. They urge reduced reporting burdens and want to prevent double reporting across different regulations.123
Why — Lower administrative costs and streamlined regulations would allow funds to focus on better social benefits.45
Impact — EU supervisory bodies may struggle to ensure regulatory consistency if reporting requirements are significantly reduced.6
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AEIP urges simplified reporting to protect retiree pension benefits

28 Nov 2023
Topic — Commission initiative to reduce reporting burdens in EU legislation by 25 percent.
Message — AEIP requests that reporting requirements be kept to a minimum. They advocate for a risk-based approach tailored to non-profit pension funds. The group calls for aligned regulations to prevent duplicate data submissions.123
Why — Cutting these burdens would prevent the erosion of benefits for pension members.4
Impact — Supervisory bodies might struggle to compare data across diverse national pension systems.5
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AEIP Urges Alignment of EU Open Finance with Pension Tracking

24 Oct 2023
Topic — The EU proposal aims to expand financial data sharing to a broader range of services.
Message — AEIP requests that the new framework builds on existing national pension tracking services. They also urge the exclusion of disability data to prevent unfair discrimination.12
Why — This approach prevents expensive administrative overhauls for non-profit pension institutions and their members.3
Impact — Pension beneficiaries face lower benefits if funds must pay for redundant data systems.4
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Meeting with Frances Fitzgerald (Member of the European Parliament, Shadow rapporteur)

27 Sept 2023 · Insolvency law

Meeting with Delara Burkhardt (Member of the European Parliament)

21 Sept 2023 · EU affairs

AEIP Urges EU to Streamline Tax Relief for Pension Funds

18 Sept 2023
Topic — This initiative proposes introducing a common, standardised, EU-wide system for withholding tax relief.
Message — AEIP requests that collective investment funds be allowed to use the new digital procedures. They also want liability for reporting errors shifted from financial intermediaries to the investors. Finally, they argue that Member States should not exclude tax-exempt pension funds from the rules.123
Why — Pension funds would gain millions in annual returns by reinvesting tax refunds much faster.45
Impact — Individual investors would face direct liability and financial recovery actions for reporting errors.67
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AEIP Advocates Paritarian Models for EU Social Sustainability

13 Mar 2023
Topic — A consultation on achieving EU economic and social sustainability by 2050.
Message — The AEIP recommends adopting a holistic approach to social policy and demographic trends. They urge the EU to support the paritarian model and collective insurance. They also call for better vocational rehabilitation services to keep people working.123
Why — Strengthening paritarian institutions would cement their members' role in managing welfare schemes.4
Impact — The traditional state-run social model faces fiscal pressure from expanding collective insurance schemes.5
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Response to Strengthening social dialogue

20 Oct 2022

AEIP welcomes the call for evidence on strengthening social dialogue in the EU and considers it as an important step towards reconciling the European growth agenda with social rights and to support the implementation of Principle 8 of the European Pillar of Social Rights (EPSR). AEIP considers that adequate and sustainable social protection systems can be designed through the paritarian model and the involvement of social partners at national and EU level. Paritarism is a type of self-organization of social relationships based upon equal negotiations between employers and employees. It leads to equally binding agreements for both parts and safeguards the interests of all stakeholders in a transparent and inclusive manner. AEIP argues for EU level support of social dialogue and collective bargaining through EU-funded projects and joint initiatives of the social partners. The EU should promote synergies between funding instruments and further foster the participation of social partners in EU-funded projects to enhance the capacity of the social partners at multiple levels. Such initiatives are crucial for strengthening ownership of the EU objectives and coordination of actions of the social partners at all levels in the areas of employment and social protection. AEIP calls the Commission to promote collective occupational schemes that ensure income protection, health and workers’ safety. For example, the Commission can make use of the European Semester to promote and enhance their role at national level, by highlighting their contribution in the workplace, which improves the efficiency of the services and contributes to the sustainability of social protection systems. Occupational schemes can also play a key role in ensuring effective coverage to categories of workers who might not enjoy the same level of protection than others, such as the self-employed and nonstandard workers. AEIP calls the Commission to set up a permanent group at EU level on LTC, where interested stakeholders could share views and practices on the matter. Despite the differences in the organization and delivery of LTC, European countries face similar challenges, such as adequacy and financial sustainability of services. While this is a national competence, a reflection at EU level would certainly be beneficial for all member states and can strengthen social dialogue. New forms of employment will need to be accompanied by new forms of social protection. While social protection systems are a national competence, AEIP believes that the EU should continue to foster a dialogue on this matter and help countries identify the best way to extend formal coverage to workers and the self-employed. Paritarian institutions are also able to provide solutions against the rising challenges of the labour market, such as vocational training and qualification of workers. Due to their involvement in cross-border situations, i.e. posted workers, paritarian institutions foster the free movement of workers, prevent wage dumping and can support the development of the internal market. The promotion of stronger collaborations among national social institutions can help to tackle labour law violations. In this context, we believe that AEIP experience can be of great support for the activities of ELA and the Platform tackling undeclared work and we hope to establish a stronger collaboration in the future. Further involvement of AEIP can strengthen social dialogue at EU and national level due to the paritarian model of the association and the members that it represents. Digitalisation has created numerous opportunities for updating social protection services. The commission should actively promote the involvement of social partners in this process. Social partners can be the useful link between public institutions and a wide range of societal stakeholders. This can help overcoming any challenge and ensure a fair transition to a green and digital economy for all.
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Response to Proposal for a Council Recommendation on long-term care

29 Mar 2022

The European Association of Paritarian Institutions – AEIP strongly supports the European Commission’s (EC) goals for the EU Care Strategy and it believes that this is an opportunity to foster the provision of long-term care (LTC) and informal care. AEIP calls the EC to promote the paritarian model across the EU as basis for sustainable and inclusive social protection. Paritarian institutions can help in implementing policy solutions in the delivery of social protection and they are key for the development of new approaches in the provision of adequate occupational healthcare and LTC benefits as well as in the management of work-life balance for workers. On healthcare and LTC, the EC should better target its Country Specific Recommendations within the European Semester and help governments to consider the resources allocated in this branch as a valuable investment rather than an economic burden. AEIP believes that an EU policy framework on LTC should consider not only patients’ clinical profile but also the family, economic and environmental context. It should also encourage stakeholders to adopt an integrated approach which would build on the synergies between social and healthcare services providers, operating both in the private and public domain. More specifically, AEIP calls on the EC: • To set up a permanent group at EU level on LTC The setting up of a permanent group (an institutionalized platform or a steering group) at EU level on LTC would increase the evidence about LTC practices within the EU. The EC should also support EU countries in developing minimum quality requirements for LTC providers to facilitate national authorities in services provision’s monitoring. • For the development of comparable data and EU indicators AEIP calls for the development of comparable data and EU indicators on LTC to support Member States in ensuring evidenced-based policies and to better target EC’s country specific recommendations within the European Semester. • For minimum quality requirements for LTC providers The development of minimum quality requirements for LTC providers would push policymakers to better monitor the provision of LTC services. This would contribute to bring decisionmakers’ attention on the fact that almost 80% of LTC in Europe is provided by informal carers. This situation negatively affects both the quality of the service that is provided to the person in need and informal carers’ personal and professional lives. • For strengthening of dependency insurance coverage The loss of autonomy, its management and occupational aspects affects all ages through disability, illness or aging and it is mainly addressed through home support provided by caregivers. This solution can be expensive and it is often not completely covered by public funds being financed by insurances. • To foster its commitment started with the EU Work-life Balance Directive to improve the social and fiscal framework in support of informal carer To address the risks entailed by the provision of LTC by informal carers, AEIP calls the EC to foster its commitment in reforming the social and fiscal framework in their support through the promotion of best practices implemented at member states level. • For workplace adaptation and working conditions flexibility AEIP believes that the EU, via its occupational safety, health, social inclusion, and equal treatment policies, could play an important role in addressing workplace adaptation and flexible working conditions. • For investing in prevention Member States should create more awareness on the repercussions that ageing has on people’s lives, labour markets and institutions of social protection. • On national policy makers to make a better use of vocational rehabilitation services At national level, policy makers should make a better use of vocational rehabilitation services. The EC should further promote human and economic resources into these services through the European Semester.
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Meeting with Astrid Dentler (Cabinet of Vice-President Dubravka Šuica)

27 Feb 2020 · Report on the impact of demographic change, Green Paper on Ageing, digitalization of services, exchange of best practices

Meeting with Ruth Paserman (Cabinet of Commissioner Marianne Thyssen)

8 Nov 2018 · AEIP Annual Conference 2018: social protection, Pillar of Social Rights, the European Semester and the social dimension of the EMU.

Response to Institutional investors' and asset managers' duties regarding sustainability

23 Aug 2018

AEIP supports a balanced approach between the disclosure obligations of market participants and the objectives of the EC Proposal for a Regulation on disclosures relating to sustainable investments Paritarian funds are natural long-term investors, due to the match between the long duration of their liabilities on the one hand, and long-term financing on the other hand. We note that freedom of investment is crucial for guaranteeing good returns as paritarian institutions invest with the purpose of maximising returns for quality social services. We stress that currently there is a lack of clarity on how ESG factors fit in the legal, regulatory and other obligations of institutional investors and the scope and definition of fiduciary duty. Therefore, in our opinion there is a need to ensure an open norm in the context of sustainable finance allowing institutional investors to take into account the sustainability aspects they consider important. AEIP stresses that any additional standards should not lead to higher costs. At this point, ESG factors are not sufficiently integrated in risk assessment methodologies in the financial sector and there is an overall lack of established best practices in this area. In addition, lack of consistent corporate disclosure regimes at the international level prevents the availability of information on ESG-related performance of investee companies. The considerable lack of data on ESG factors, together with the current differences in national legislations and practices create a risk for the new rules on disclosure to rise costs substantially. Currently the involvement of external managers and data collection agencies for this kind of tasks seems to be a standard practice in various MSs. In countries where there is no direct legislative obligation for the integration of ESG factors, the costs will be significantly higher. We want to stress on the need to ensure a cost-benefit approach to disclosure i.e. disclosure obligations should not create a heavy burden for institutional investors. The technical standards that will be proposed by a Joint Committee of the ESAs and finally adopted by the EC have to be well-defined, flexible and non-excessive as well as fully in line with the principles of subsidiarity and proportionality. AEIP is against delegated acts for the IORP Directive and calls both the EC and its Technical Expert Group on Sustainable Finance to work closely together with stakeholders – at national and EU level- and consider their input through regular consultations, with the aim of defining the prudent person rule and the scope of the disclosure obligation in line with the current provisions of the IORP II Dir that is being currently implemented by the Member States. Reporting obligations should be complementary to the existing rules for the disclosure of non-financial information. Companies need incentives to implement an ESG policy affecting economic and financial decision-making. For this reason, we would like to promote a long-term perspective for investments and long-term sustainability. Given the difficulties for instit. investors to assess impacts and disclose investment information on ESG factors, AEIP suggests a longer transitional period for the implementation of the Regulation. In the context of prudential supervision, including ESG factors in prudential requirements (against risks) requires in the first place capacity building and sharing of best practices. As social protection institutions we would also like to stress the importance of the social factor in sustainable finance. Poor social protection, limited social inclusion and poor working conditions present societal risks that damage financial stability and the continuity of paritarian institutions. In particular, more attention should be paid to drivers of social impact investment. We invite the EC to consider social and governance aspects beyond environmental aspects.
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Response to Institutional investors' and asset managers' duties regarding sustainability

23 Aug 2018

Sustainable finance is the cornerstone for the success of the Capital Markets Union. The European Association of Paritarian Institutions embraces the EC action and legislative proposals to facilitate sustainable investments and the new standards for an EU green bond. Paritarian funds invest with the purpose of maximising the result for quality social benefits, reflecting the long-term commitment and engagement with their schemes members. In the context of sustainable finance AEIP’s preference goes to an open norm allowing institutional investors to factor the sustainability aspects their members consider important. We support the development of a taxonomy for sustainable activities as it is the cornerstone for sustainable finance. It helps to make investments in (environmental) sustainability more accessible and align criteria. Such an EU-wide classification system contributes to better comparability and will help all market participants. However, in that case sufficient flexibility is necessary and should be regularly built in. The taxonomy should be adjusted to new developments. A link with the UN SDG’s is desirable including the dimension of governance and social aspects. The focus of the taxonomy should be on products and services. At the same time it has to be ensured that sustainable products and services are produced in a responsible and sustainable way. The purpose of a taxonomy should be guiding and not resulting in pressure towards specific investments / divestments. The methodology for designing the proposed technical screening criteria (but also the benchmarks on low-carbon & positive carbon impact) should be clear, transparent, empirically-based and universally applicable. The aim should be that end-investors are able to easily compare sustainable investments. Investors require tangible ESG factors in order to quantify them with the ultimate aim to make better investment decisions and risk analysis. Due to the evident heterogeneity of pension funds throughout Europe, the principle of proportionality should be leading when designing the appropriate measures. We appreciate the establishment of the technical criteria based on assessment at sectoral and sub-sectoral level. Importantly, the criteria should take into consideration the “cost-benefit trade-off” which is applicable to the various stakeholders. These criteria should not form an exclusive list, but serve as guidelines, which should also allow for a level of flexibility. AEIP supports the approach to make an ex-ante impact assessment analysis, before the adoption of each delegated act establishing the technical screening criteria, in order to define the nature and magnitude of the costs on stakeholders. First and foremost, capacity and tools have to be built up and developed before considering ESG factors in the future in prudential supervision. As social protection institutions we would also like to stress the importance of the social factor in sustainable finance. We would like to stress on the importance of the consistent and balanced consideration of the accepted definition of “sustainability” (UN Brundtland Commission), including all aspects of sustainability (climate change, environment, social & governance factors), in order to ensure no imbalances are resulting from focusing on certain aspect over others. Poor social protection, limited social inclusion and poor working conditions present societal risks that damage financial stability and the continuity of pension funds. We invite the EC to consider the S and G aspects beyond environmental aspects, as these have been framed through the Pillar of Social Rights. In order to reach the desired level of functionality, there must be a substantial amount of data provided by companies. Data should be of good quality, be easily standardized and compared by end-investors. Moreover, AEIP is in favour of a number of control measures for the implementation of measures against “green washing”.
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Response to Review of the European Supervisory Authorities

23 Jan 2018

Paritarian institutions are active on financial markets AEIP’s members are paritarian institutions of social protection in the field of pensions & healthcare insurance. They are subject to national social and labour law (SLL) and under national supervision. At the same time they are using financial markets to increase return on investment for achieving a good level of benefits. As institutional investors we support further integration of capital markets.In this respect, we still encounter barriers when investing abroad, due to differences in legal systems or administrative requirements and sometimes to discrimination of foreign investors. Such barriers should be progressively removed. AEIP believes that supervisory convergence can help in this regard. This is not the case if we consider paritarian institutions as institutions with a social objective e.g. in the context of occupational plans the opportunity for supervisory convergence is limited. Convergence of supervisory practices is different in a framework of minimum harmonisation. We support a common supervisory culture in a sense of coordination & share of best practices, but not a supervisory convergence that leads to "a one-size-fits-all" supervisory approach. ESAs Governance: Proper checks and balances needed NCAs should stay independent in deciding on the supervisory policy for national paritarian institutions - as pension funds & healthcare insurers - which are based on national SLL. Regarding ESAs’ role, we think that any guidelines/recommendations shall remain non-binding measures.With time guidelines/ recommendations have become "soft regulation" which appears as binding. This state of play shall be reviewed. With regard to capital markets, ESAs can and should play a greater role. Also in this respect, the added value of NCAs needs to be preserved. A right balance needs to be struck between maintaining the NCAs’ current roles and enhancing ESMA’s role in mainly creating more supervisory convergence. For capital markets, we think that there is strength in combining both the national and European factors, rather than replacing the one by the other. We see an important role for the EC, the Council and the EP in the supervision of the ESAs, in order to check whether their operations align with the set responsibilities. The governance structure of EIOPA needs to ensure sufficient knowledge and expertise about specificities of occupational plans or social protection insurance plans (healthcare, death & disability) ESAs Financing Insurance & occupational pension supervision in Europe is mainly in the hands of national supervisory authorities we consider good & independent supervision to be important. However, shifting the funding of the ESAs to the industry is not the right way forward. In this respect it is also important to take into account the triangle between regulators (in this case the EC & national governments), the supervisory authorities and the institutions that are being supervised. Supervisory budgets need to be subject to adequate checks and balances. The budgets of the ESAs needs to be closely monitored by the EU budgetary procedure ESAs Operation -Comparing stress test results between individual IORPs has little added value, since the results should be interpreted within the national supervisory framework – which differs from country to country -Reducing and streamlining reporting requirements should be high on the priority list. Data, including those for statistical purposes, should only be collected by national NCAs -We welcome that the ESA Review Package aligns with the Better Regulation Agenda, when implementing and carrying out cost-benefit-analyses should always be the driving force -A continuous dialogue between supervisor and supervised entities is at the core of efficient and effective supervision -There should be no bank bias within the ESRB, neither in its approach to other financial sectors nor in its govern
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