In submissions to the review, the German ministry of finance insisted it would resist any proposals deemed to "weaken" the country's pension system, and urged the European Commission to conduct "unbiased" impact studies on any proposed changes. The UK's Treasury criticised that the arguments in favour of reform – to introduce an even playing field between the insurance industry and pension funds, as well as to allow for a greater number of cross-border schemes – required proposals of "such magnitude" and carried "such a high risk" that they were "highly disproportionate to the problems they purport to address".
The Dutch ministry for social affairs, meanwhile, questioned the Directive's approach to a "holistic balance sheet" (HBS), saying several areas still required clarification. It said it was currently unclear how the Directive would distinguish between unconditional, conditional and discretionary payments. "This is an interesting distinction, but it is not clear to us how the allocation of the benefits will be made", the ministry said, arguing that the impact of HBS would be largely dependent on how such factors were interpreted and that the differentiation would have "tremendous consequences".
Directly questioning how the new regulations would impact the country's system of rights cuts – employed in case a scheme is unable to meet certain funding requirements – it called on EIOPA to "better illustrate" how such changes would be accounted for within the new balance sheet approach.
However, counter to the responses from Germany, the UK and the Netherlands, the French Treasury endorsed the notion of "same risk, same rules" in its submission. The Direction Générale du Trésor said it was "essential" to have a uniform level of security across the common market. "For reasons of consistency, the Solvency II parameters should apply to IORPs", it said.
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