IORP II reporting explained: what pension funds send to EIOPA and the national authority, and when

IORP II is the EU directive for occupational pension funds, and the reporting that comes with it runs on two tracks that are easy to confuse. One goes to EIOPA through the national supervisor, on a fixed set of PF templates in XBRL. The other stays national: whatever the supervisor asks for under its own rules. This article sets out who is in scope, what the EIOPA package contains template by template, when each file is due, which taxonomy version to build against, and what the 2025 review proposal means for reporting. It is written for the person who has to produce the file, in the fund or at its administrator. The templates in the table below are the ones IORP Tool populates and validates before submission, so the codes are printed the way EIOPA prints them.

What IORP II is

Directive (EU) 2016/2341 on the activities and supervision of institutions for occupational retirement provision was adopted on 14 December 2016 and published in the Official Journal on 23 December 2016. Article 64 required Member States to transpose it by 13 January 2019, and Article 65 repealed the first IORP directive, Directive 2003/41/EC, with effect from the same day. It is a recast of the 2003 text with new chapters on governance, the own-risk assessment (Article 28), the pension benefit statement and cross-border activity.

The directive says almost nothing about templates. Article 50 gives supervisors the powers and means to obtain information from an IORP; it does not say what form that information takes. The PF templates come from elsewhere, which is where most of the confusion starts.

Who is in scope

The directive covers any IORP registered or authorised in a Member State. Under Article 4 a Member State may also apply it to the occupational pension business of a life insurer, with the assets and liabilities ring-fenced.

Article 5 is the small fund exemption. A Member State may choose not to apply the directive, in whole or in part, to an IORP whose schemes together have fewer than 100 members, except for Articles 32 to 35 on the depositary and the actuarial function. A fund with more than 15 members must still meet the investment rules in Article 19(1) and the governance rules in Article 21(1) and (2). Whether a country has used the option is national law.

The EIOPA reporting package adds its own thresholds, and they are not the directive’s:

• An NCA must report individually, rather than inside a national aggregate, every IORP with a balance sheet above EUR 1,000 million, and every IORP between EUR 100 million and EUR 1,000 million that is among the five largest in the country.
• An NCA may keep the smallest funds out of quarterly reporting and out of the item-by-item list of assets, as long as the funds that do report quarterly cover at least 80 percent of the sector’s balance sheet.
• An NCA may exempt from the full annual set funds with total assets under EUR 50 million or fewer than 100 members including beneficiaries, until the exempted funds reach 20 percent of the sector. A fund operating cross-border is expected to report from EUR 25 million. Exempted funds still file a reduced annual set.
• A fund that crosses a threshold, in either direction, changes status only after three consecutive reported years on the other side.

So a fund can be inside the directive and outside quarterly EIOPA reporting, or exempt under Article 5 and still on the supervisor’s own annual return. Check the two lists separately.

Two reporting streams, not one

The first stream goes to EIOPA and the ECB. EIOPA’s legal basis is Article 35 of Regulation (EU) No 1094/2010, which lets it request information from national supervisors at recurring intervals. The instrument is the Decision of the Board of Supervisors on EIOPA’s regular information requests regarding provision of occupational pensions information. The first version, EIOPA-BoS-18/114, was adopted in April 2018 and started with the third quarter of 2019; a June 2020 amendment realigned the templates with the Solvency II taxonomy. The current version, EIOPA-BoS-23-030 of 10 February 2023, applies from 1 January 2025, repeals the 2018 decision from that date, and closes data gaps found in the first three years.

The ECB collects statistics from the same funds under Regulation (EU) 2018/231 of the European Central Bank of 26 January 2018 on statistical reporting requirements for pension funds (ECB/2018/2). It applies to pension funds resident in the euro area and also started with the third quarter of 2019. The ECB’s requirements are carried as add-on rows and columns inside the PF templates, with their own technical instructions from the ECB, so a euro area fund produces one file that serves both institutions and a fund outside the euro area produces the EIOPA content only.

Formally the EIOPA decision binds the NCAs, not the funds; the NCAs collect under national powers such as Article 50. In practice most NCAs pass the PF templates through unchanged and ask for XBRL, so the fund experiences the decision as if it were direct law.

The second stream is the national supervisor’s own return, and it varies far more between countries than anything under Solvency II: the annual accounts with the actuarial report, a national funding or solvency return, cost reporting under EIOPA’s 2021 opinion on costs, and in several countries extra national validations on the PF templates themselves. None of that is in the EIOPA decision.

The EIOPA pension templates

The table lists the templates in the 2023 decision. In the taxonomy each code carries a variant suffix, and the same template appears with a different suffix in the aggregate set: PF.06.02.24 for an individual fund, PF.06.02.26 for a national aggregate. PF.01.01 is the content template that lists which of the others are in the file.

Funds exempted under the EUR 50 million or 100 member rule file a reduced annual set: PF.01.02, PF.02.01, PF.50.01 and PF.51.01, each under its own variant suffix.

Valuation follows two rule books inside one file. Assets are valued on a market-consistent basis, with quoted prices in active markets as the default. Liabilities and everything else follow national accounting or prudential rules, so PF.29.05 is not a Solvency II technical provisions movement, whatever its shape suggests. For quarterly files the decision allows reasonable estimates for liabilities, and where technical provisions are valued annually the NCA may carry the last annual figure through the quarters.

The list of assets is where the work is. PF.06.02 needs an identifier, a CIC code, issuer and issuer group, country, currency, quantity, price and value for every holding, and PF.06.03 needs the same through each fund the IORP holds. Anyone who has run asset reporting for an insurer will recognise it; the Solvency II QRT list shows the S.06.02 template it was modelled on.

Deadlines

The EIOPA decision fixes the deadline for the NCA to EIOPA: nine weeks after the end of the quarter for quarterly data and 20 weeks after the year end for annual data. The NCA has to receive, validate and forward the files inside that window, so national deadlines to the funds sit earlier, and they differ by country.

The ECB regulation sets its deadline for the fund itself. Article 8 started quarterly data at ten weeks after the quarter end in 2019 and shortened it by one week a year to seven weeks from 2022; annual data started at 20 weeks and shortened by two weeks a year to 14 weeks from 2022. Where a euro area fund files one combined file, the tighter ECB deadline is the one that binds.

Before the file leaves the fund it has to pass the validation rules EIOPA publishes for that reporting period, taxonomy checks and filing rules together. The NCA applies them before forwarding, and EIOPA checks completeness after the deadline. A file that fails at the NCA comes back, and the calendar does not move.

Taxonomy versions

EIOPA publishes the Pension Funds taxonomy separately from the Solvency II one. Pension Funds 2.9.0 was published as a hotfix on 16 July 2024 and applies from the 1 January 2025 reference date; it is the release that carries the 2023 decision’s template set. A second hotfix of 30 June 2025 added optional NACE 2.1 classification alongside NACE 2.0 on the same 2.9.0 line. The previous release, Pension Funds 2.7.1, covered reference dates up to the fourth quarter of 2024.

The rule that catches people is that the version follows the reference date, not the filing date. A resubmission of a 2024 file uses 2.7.1 even if it is sent in 2026, so a tool has to hold every version still in use and pick by period. The XBRL mechanics are the same as on the insurance side; what XBRL is and how the EIOPA taxonomies work covers them.

The IORP II review

EIOPA delivered its technical advice on the review of the directive on 28 September 2023 (EIOPA-BoS-23-341). On 20 November 2025 the Commission published a supplementary pensions package that includes a proposal to amend Directives (EU) 2016/2341 and 2016/97, COM(2025) 842. On 26 June 2026 the Member States’ ambassadors approved the Council’s negotiating mandate, which keeps the structure of the Commission text and adds national options.

The proposal works on the directive, not on the EIOPA decision or the ECB regulation, so the PF templates and their deadlines are untouched by it. What it touches is the information flow around the fund. The Commission text included a transmission of information to national pension tracking systems, a regular supervisory dialogue between the NCA and the fund, an internal stress test, and an article on underperformance against benchmarks. The Council’s mandate removed the transmission to tracking systems and the systematic supervisory dialogue, left stress test parameters to national choice, and replaced the benchmark article with a duty to review the benchmarks in the fund’s own statement of investment policy principles. It also raised the proposed ceiling for investment in listed shares and bonds to 100 percent, against 70 percent in the Commission text, and strengthened proportionality in supervision.

The Parliament’s ECON committee planned to adopt its report in October 2026, after which the three institutions negotiate. Until a text is agreed and transposed, the obligations above are the ones that apply.

Where this lands in the software

IORP Tool holds the PF templates for every taxonomy version still in use and picks the version by reference date. Data is pulled in from databases, Excel files and CSV files through transformations that are defined once and reused quarter after quarter, so the list of assets is built from the custodian file rather than typed. The validation rules for the period run before submission, and the resolvers fix the common validation errors automatically; in several countries the national supervisor’s own additional validations are built in as well. SmartData, the embedded asset repository, fills the missing fields on PF.06.02 and PF.06.03 by ISIN, with LEI and ultimate parent data from the Global Legal Entity Identifier Foundation. The output is the XBRL file the NCA forwards to EIOPA.