EUROPE - The European Commission's Call for Advice (CfA) on the revision of the IORP directive has raised concerns at the European Federation for Retirement Provision (EFRP).

Chris Verhaegen, chief executive at the EFRP, told delegates at the annual conference of German occupational pension association aba that the CfA had come too soon and relied too heavily on Solvency II.

Earlier, Jung-Duk Lichtenberger had told aba members the Commission's issuance of the CfA last month to pensions and insurance supervisory body EIOPA covered a number of questions.

These ranged from who might be included under the directive to how to simplify pan-European schemes, how to introduce a risk-based supervision and how to deal with purely defined contribution schemes.

But Verhaegen said the EFRP was worried the CfA sent to EIOPA had taken Solvency II as a "benchmark" for risk-based supervision.

"We would have hoped for more creative ideas, and we will propose an alternative to this that will hopefully be met with sufficient attention so we can walk away from the Solvency II straitjacket," she said.

Verhaegen also questioned the timing of the CfA, adding that she would have preferred to have seen the EU's White Paper on pensions first. Lichtenberger promised this for September 2011.

The EFRP's head demanded an in-depth analysis of all responses to the Green Paper consultation, arguing that this had yet been done yet.

"Just one month after the closure of the consultation, we saw the first conclusions - a real Herculean feat for the commission to have accomplished, given that 1,600 responses were filed," she said.

She urged the Commission to do other "necessary groundwork" before proceeding with any discussions on the pension system, such as the mapping of the various pension systems in EU member states.

"It should start by creating a matrix and a map of the pension systems, including all pillars, to create an understanding of what is the first, second and third pillar in the individual countries to then be able to compare systems - this would also help transferability," she said.

"Instead of doing this groundwork - which is tedious, and not only very technical but also political - they are first coming up with legislation and then considering the impact of that legislation."

She particularly criticised the treatment of the new member states that have mainly introduced pension reform according to the World Bank model.

"I have the impression that the EU15 have so far left the new member states out," she said, adding that, so far, mainly Western European pension models had been considered.

"The current IORP directive applies to 27 member states, but it is only relevant in six or seven member states - this has to change, so any new directive has to include all work related pensions," she said.

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