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PensionsEurope also stressed the importance of taking into account the labour and social aspects of occupational pensions when adopting new rules for the sector, and therefore refused the application of insurance legislation to workplace pensions. Insurance legislation cannot be used to regulate workplace pension schemes due to their specific characteristics and risks. In addition, the principles of subsidiarity and proportionality should play a key role given the diversity of occupational pension schemes across the EU and the different role of the social and labour law in each Member State.
As far as the involvement of stakeholders is concerned, PensionsEurope would like to highlight the need for extending the timeframes given to stakeholders to respond to the consultations. This would increase the number and representativeness of stakeholders that participate in the consultations and increase the quality of the input provided. The representativeness in the different advisory stakeholder groups should also be improved in terms of type of market participants, size and jurisdiction. PensionsEurope also proposed to increase the timeframes given to stakeholders to respond to the consultations and requested that ESMA's stakeholder advisory group counts at least with two representatives of the pensions sector.