The IORP II review: what the 2025 Commission proposal and the June 2026 Council position mean for reporting teams

The IORP II directive is being rewritten, and the reporting team of a pension fund is the group most likely to be asked what it means before anyone knows. This article sets out where the review came from, what the Commission put on the table on 20 November 2025, what the Council took off it on 26 June 2026, where the Parliament is, and how long it will take. It stays with the parts that change the data a fund produces, read from the two legislative texts rather than from summaries. The PF templates a fund files today do not change through any of this, which is why IORP Tool keeps building the current templates and validations while the review runs. What a fund can do now is get its data ready for the version that survives.

Why the directive is under review

Directive (EU) 2016/2341 told the Commission to review it by 13 January 2023. The Commission sent EIOPA a call for advice in June 2022; EIOPA consulted on a draft in spring 2023 and delivered its final technical advice, EIOPA-BoS-23-341, on 28 September 2023.

One item in that advice is the seed of everything that matters here. Under “effective use of data”, EIOPA noted that the directive never mentions regular quantitative reporting, so some supervisors lack a clear national power to set the content and deadlines of regular returns, and some found it hard to justify passing data to EIOPA. The advice asked for an explicit empowerment in the directive. The other items were proportionality, liquidity risk, conflicts of interest, cross-border transfers, the pension benefit statement and the shift from defined benefit to defined contribution.

The review then merged into the Savings and Investments Union agenda. The Commission consulted again in June 2025, received EIOPA’s technical input, EIOPA-BoS-25-418, on 8 September 2025, and published the proposal ten weeks later inside a package with a PEPP revision and a recommendation on tracking systems and auto-enrolment.

What the Commission proposed on 20 November 2025

COM(2025) 842, procedure 2025/0362(COD), amends Directive (EU) 2016/2341 and, for tracking system data from insurers, Directive (EU) 2016/97. In outline: authorisation replaces registration for new IORPs (Article 9); cross-border procedures and transfers are simplified (Articles 11 to 12a); the prudent person principle becomes more principles based, with a floor of 70 percent for listed shares and corporate bonds (Article 19); governance, member information and supervision are all tightened; and transposition is due two years after entry into force.

Five articles reach into the data a fund produces.

Article 50 is the one EIOPA asked for. Member States must require IORPs to submit the quantitative and qualitative information necessary for supervision, and the supervisor decides its nature, scope and format. The supervisor may require regular quantitative templates, explicitly including the information EIOPA requests under Article 35 of Regulation (EU) No 1094/2010. Every fund must also report annually its investment returns net of costs and all costs and charges, on a look-through basis with a no-netting rule, on formats set by EIOPA implementing technical standards.

Article 41a sets up benchmark monitoring. The supervisor develops benchmarks for costs, returns and funding outcomes; the fund informs the supervisor promptly of a material deviation, and tells its members if it persists for three years.

Article 49a creates a regular supervisory dialogue built on early warning parameters such as costs, net return and shortfalls against promised benefits, with a remedial plan where it finds weaknesses.

Article 18a requires funds that themselves underwrite biometric risk or guarantees to run a stress test at least every three years: ten-year projections under a baseline, a fixed interest rate shock, a 30 percent fall in asset returns and a 10 percent fall in mortality, with a convergence plan if the test fails.

Article 37a requires funds to transmit to national pension tracking systems, where they exist, everything needed for a complete overview of a member’s entitlements, in a standardised, machine readable format.

What the Council changed on 26 June 2026

The Council Working Party met seven times between 1 December 2025 and 10 June 2026, and on 26 June 2026 Coreper confirmed the text in Presidency note 10759/26 as the mandate for negotiations with the Parliament. The Council kept the architecture: authorisation, the cross-border and transfer chapter, the governance changes and the duty of care all survive. What changed is mostly what was taken out or handed back to Member States.

Article 50 keeps its opening empowerment word for word. The point on regular templates now says the supervisor may “where necessary” request quantitative information, “including, where applicable, for the purposes of cooperation with EIOPA”. The annual report of net returns and all costs stays, but “only where relevant and only if relevant for supervisory purposes as decided by the competent authorities”. The look-through rule, the no-netting principle and the EIOPA technical standards are gone.

Article 41a is deleted. In its place Article 30 says an IORP must review the benchmarks in its own statement of investment policy principles, compare its performance against them on a multi-year annualised basis in gross and net terms, and act where performance materially deviates over a rolling period. The benchmarks are the fund’s, not the supervisor’s, and there is no member notification. Article 49a and Article 37a are deleted outright, and Article 18a stays but loses its numbers: the horizon becomes “midterm to long term” and the scenarios are “to be specified at national level”. The rest is in the table.

Proposal against Council position

Where the Parliament stands

The Committee on Economic and Monetary Affairs has the lead. Damian Boeselager (Greens/EFA) was appointed rapporteur on 5 February 2026 and tabled his draft report on 2 June; amendments followed on 7 July and the Employment committee’s opinion on 6 August. The committee’s published timetable, as circulated by PensionsEurope in May 2026, has the vote on the report and on entering negotiations on 15 October 2026; the procedure file still shows the file as awaiting committee decision.

The draft report goes the other way from the Council on tracking systems, which it wants to strengthen rather than delete. Nothing in it is the Parliament’s position until the committee and then the plenary vote.

A realistic timeline

Nothing below is a date in any text; it is arithmetic on the dates that are. If ECON votes on 15 October 2026 and the plenary confirms the mandate, trilogues can open in late 2026 or early 2027. The gap between the two mandates is wide on benchmarks, dialogue and tracking systems, so agreement late in 2027 is more likely than early. Revision, adoption and publication add months, and entry into force is 20 days after publication.

Both texts then give Member States two years to transpose, so the earliest plausible application date is 2029, and 2030 is as likely; the first directive gave three years and many Member States still missed the January 2019 deadline. Until national law changes, a fund’s obligations are the current directive, the EIOPA decision and the ECB regulation, which the article on what pension funds send to EIOPA and when sets out template by template.

Does the review touch the Pension Funds taxonomy?

Not directly. The PF templates are set by EIOPA’s Board of Supervisors decision EIOPA-BoS-23-030 and the ECB’s Regulation (EU) 2018/231, neither of which the proposal amends. EIOPA’s release roadmap of 15 July 2026 lists Pension Funds taxonomy 2.9.0, or its NACE 2.1 hotfix, for every reference date to 31 December 2027.

The indirect route runs through Article 50. Once the directive says that supervisors may require regular quantitative templates, including data for EIOPA, the legal footing EIOPA said it lacked in 2023 is there, and a later revision of the reporting decision becomes easier to justify; the Council’s qualifiers soften that without removing it. The annual cost and return report is the likelier first change, arriving as national templates or as an addition to the PF package on the XBRL mechanics described in what XBRL is in insurance and pension reporting. None of that happens before the directive is adopted.

What to prepare now

The work worth doing before the text is final is data work, because the data survives whichever version passes.

Costs and charges on a look-through basis come first. The Commission wanted them mandatory, the Council makes them conditional, and EIOPA’s 2021 opinion on cost reporting already asks supervisors to collect them. A fund that can produce its costs through its funds and managers, and returns net of those costs over multi-year periods, is ready for either outcome.

Benchmarks are second. Under the Council text the fund compares itself with the benchmarks in its own statement of investment policy principles, so those need to be ones the fund can measure on a rolling multi-year basis, gross and net. A statement that names no benchmark, or one nobody calculates, becomes a finding.

For funds that carry biometric risk or guarantees, a multi-year projection of assets and liabilities under a baseline and adverse scenarios is coming in some form. The Commission fixed the shocks and the Council leaves them national; the projection engine is the same either way. Tracking system feeds depend on the Parliament: if Article 37a returns in a compromise, a machine readable extract of accrued rights, capital and projected benefits per member will be needed, and that can wait for the trilogue outcome.

None of this changes the quarterly and annual PF filings; the deadlines, taxonomy version and validation rules for the fourth quarter of 2026 are what they were before the review started.

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, so a change to the EIOPA decision arrives as a new version alongside the old ones rather than a migration. Data comes in from databases, Excel and CSV files through transformations that are defined once and reused, which is where a cost or return report built on a new template would be mapped when it exists. The period’s validation rules run before submission, the resolvers fix the common errors automatically, and national supervisors’ extra validations are built in for several countries. SmartData fills issuer, LEI and parent data on the list of assets by ISIN. The output is the XBRL file the supervisor forwards to EIOPA.