Kommisjonsrekommandasjon (EU) 2025/2384 av 20. november 2025 om pensjonssporingssystemer, verktøy for overvåking av pensjonssystemer og automatisk innmelding
EU-henstilling om pensjonssporingssystemer
Kommisjonsrekommandasjon publisert i EU-tidende 27.11.2025
Bakgrunn
(fra kommisjonsrekommandasjonen)
(1) The report of the European Parliament Committee on Economic and Monetary Affairs of 10 September 2025 on facilitating the financing of investments and reforms to boost European competitiveness and creating a Capital Markets Union (Draghi Report) (2024/2116(INI)) emphasises that pensions help protect pensioners, build capital markets and mobilise investment, and specifically urges the Commission to ensure that all Member States introduce simple and transparent pension tracking systems.
(2) The Eurogroup in inclusive format in March 2024 invited (i) Member States to assess the availability of products for their citizens in the occupational pensions market and to share best practices, including on how to improve citizens’ enrolment in occupational pensions; (ii) the European Commission to inform Member States’ efforts by identifying and proposing best practices; (iii) Member States to develop pension tracking systems to provide their citizens with an overview of future retirement income; and (iv) the European Commission to develop a pension dashboard in collaboration with the European Insurance and Occupational Pensions Authority and Member States.
(3) The Statement of the Euro summit of April 2024, called on all Member States and EU institutions to ensure the swift implementation of all the measures outlined in the statement of the Eurogroup in inclusive format mentioned above.
(4) The European Commission Communication of 19 March 2025 on ‘Savings and Investments Union: A Strategy to Foster Citizens’ Wealth and Economic Competitiveness in the EU’ sets out the Commission’s commitment to promote the use of and best practices for pensions tracking systems, pension dashboards and auto-enrolment to increase people’s awareness about their expected retirement income so that they can better prepare for retirement. Such tools would contribute to unlocking greater scale and depth of occupational pensions markets, which would benefit not only people, but the Union economy at large;
(5) The special report of the European Court of Auditors on supplementary pensions of May 2025 recommends that the Commission improve the transparency of data on pension gaps, both for individuals and at country level, by advancing its policy action on pension tracking systems and dashboards.
(6) The December 2019 report of the High-level group of experts on pensions advised Member States to take a long-term and comprehensive approach to developing multi-tier pension systems, and provided recommendations to the EU institutions, Member States, pension providers and social partners on how to accomplish this.
(7) The June 2020 report of the High-level forum on the Capital Markets Union warns that pension inadequacy risks pose political and budgetary challenges for Member States, and recommends that the Commission (i) develop a dashboard to measure Member States’ progress on pension adequacy and sustainability; (ii) encourage the development of pension tracking systems for individuals; and (iii) support the introduction of auto-enrolment systems to ensure adequate pension coverage across all Member States.
(8) The 2021 study on best practices on auto-enrolment conducted on behalf of the European Commission, and the technical advice of the European Insurance and Occupational Pensions Authority on best practices for pension tracking systems and pension dashboards, along with its additional technical input of September 2025 to the reviews that were conducted as part of the Savings and Investments Union, provided further input in these areas.
(9) The 2024 Pension Adequacy Report, jointly prepared by the European Commission and the Social Protection Committee, and the 2024 Ageing Report which projects age-related public expenditure over the next decades, jointly prepared by the European Commission and the Economic Policy Committee, inform the Commission about current and future pension adequacy and key challenges across the EU, and the sustainability of public finances, respectively.
(10) Principle 15 of the European Pillar of Social Rights stipulates that workers and the self-employed have the right to a pension commensurate to their contributions and ensuring an adequate income, and women and men shall have equal opportunities to acquire pension rights.
(11) The Council Recommendation of 8 November 2019 (1) on access to social protection for workers and the self-employed includes a recommendation for Member States to ensure the transparency of the conditions and rules for social protection schemes, and that individuals have access to updated, comprehensive, user-friendly and clearly understandable information about individual entitlements and obligations free of charge. Member States are also recommended to simplify, where necessary, the administrative requirements for workers, the self-employed and employers to access and benefit from social protection.
(12) As low financial literacy and cognitive and behavioural biases can hamper retirement planning, measures for the promotion of financial education and pension transparency are necessary. The Eurobarometer of July 2023 revealed such biases in a significant share of the population. The Council Conclusions of 14 May 2024 called on Member States and the Commission to take wide-ranging measures to increase financial literacy in the EU, including to enable people to prepare and invest for the future. As a response to this call, on 30 September 2025 the Commission published a strategy on financial literacy setting out initiatives that aim to empower people to make more informed decisions as regards long-term planning including retirement planning.
(13) Alongside financial education measures, effective information tools will need to be made available to enable people to engage in financial planning for retirement. Many Europeans lack data and tools to keep track of their pension entitlements, which are increasingly spread across different schemes and – increasingly – countries, creating challenge in making informed decisions about career, retirement and savings needs. Raising awareness on the impact of career choices, such as career breaks and part-time employment, on retirement age and savings would enable beneficiaries, especially women, to take well-informed decisions. A national pension tracking system (PTS), a digital tool providing a consolidated overview of accrued entitlements and, ideally, projected pension benefits from all sources, can foster transparency and awareness, and build trust in the pension systems, thereby enabling individuals to better assess the future adequacy of their retirement income and make informed decisions. While most Member States have dedicated online information platforms for pension entitlements, these are often limited to public pensions and lack comprehensive coverage of supplementary pensions. Only a few Member States currently provide a PTS that includes comprehensive information about all pillars and providers.
(14) Member States should make a comprehensive PTS available to their population. This is to fill the pension information gap and empower individuals to assess and, if necessary, enhance their current and future pension income adequacy. EIOPA’s technical advice includes good practices for the design, governance and implementation of national pension tracking systems. To be effective, a PTS must feature a user-centric design that accounts for the needs and cognitive biases of the average individual. This involves presenting information in a simple and understandable way, using plain language, and employing a multi-layered approach where essential information is prioritised on a landing page. Detailed information on future benefits should also be provided to users that wish to delve deeper. Member States should also ensure that their PTS complies with the requirements of the European Accessibility Act (Directive (EU) 2019/882 of the European Parliament and of the Council (2)) and the Web Accessibility Directive (Directive (EU) 2016/2102 of the European Parliament and of the Council (3)).
(15) The European Commission is supporting the development of the European Tracking Service (ETS) – a pan-European platform intended to serve as a central hub, connecting the various national PTS across the EU. The ETS should enable mobile workers to obtain an overview of their pension entitlements, regardless of the Member State in which they were accrued. A prerequisite for effective cross-border pension tracking is that the national PTS are set up and designed, or adapted, to be technically interoperable and authorised to share data with the ETS.
(16) Demographic trends, the impact of technological developments on employment, and new forms of work are posing increasing challenges to the adequacy and sustainability of pension systems across the EU. The average public pension in the EU as a percentage of average gross wage is set to decrease in the next decades. However, there are notable differences across the EU in the structure of pension systems, and in pension entitlements between different age groups, genders, sectors, earning levels, career durations and paths. This implies uneven pension adequacy across the population.
(17) In the face of demographic pressure, most Member States have reformed their pension systems, which in many cases may lead to lower public pension replacement rates. Despite several sustainability-enhancing reforms, public pension systems in many Member States remain under pressure. In the meantime, occupational and personal pension schemes are playing an increasing role in supplementing public ones to ensure that pensioners will have an adequate retirement income, while maintaining the sustainability of the system. However, supplementary pensions have remained underdeveloped in many Member States, and their coverage varies across the population due to a combination of factors such as differences in saving capacity, insufficient financial literacy and transparency, and lack of trust in the supplementary pension sector’s capacity to deliver net real growth of savings. Access to occupational pensions hinges on the type of employment contract, the employment sector, the size of the employer, as well as on the strength of collective bargaining systems and social dialogue in this regard. Efforts should be made to facilitate access to supplementary pensions through a comprehensive approach that caters to different groups of the population.
(18) As the responsibility to organise pension systems lies with Member States, this Recommendation is intended to provide guidance on the introduction and, where relevant and necessary, the review of pension tracking systems, pension dashboards, and auto-enrolment frameworks. The objective is to increase individuals’ awareness about their expected overall retirement income stemming from all pension pillars, and help them prepare better for retirement, and to improve the ability of Member States to assess and review the sustainability and adequacy of their pension systems, including across different demographic groups. The Recommendation considers the views and advice from stakeholders gathered through consultations, and evidence on the socioeconomic impacts of pension tracking systems, pensions dashboards, and auto-enrolment.
(19) In several Member States, social partners play a fundamental role in the governance and design of occupational pension funds, in the exercise of their autonomy and collective bargaining prerogatives. This model of shared responsibility, grounded in social dialogue, has proven highly effective in ensuring the provision of robust occupational retirement. It has been shown to foster ownership by workers and employers, and to enhance the long-term sustainability, adequacy, efficiency and transparency of occupational pension funds, as well as their alignment with the economic and social interests of both workers and employers. In some Member States where occupational pension schemes are less developed, employers match their workers’ contributions to their personal pensions. This contribution is reflected in the pay package of workers, and serves to enhance pension income.
(20) Communication to the public on pensions’ reform needs and their impacts can only be credible if it is objective and based on reliable data. When long-term pension reforms are designed, it is crucial that Member States are able to base policy decisions on comprehensive and sufficiently forward-looking information on both public and supplementary pensions. However, while most Member States collect statistics on supplementary pension funds and their members, in addition to extensive data on public pensions, only few have data and tools to systematically monitor the overall adequacy and sustainability of their multi-pillar pension systems.
(21) The purpose of pension dashboards is to help Member States monitor changes in pension coverage, adequacy and sustainability across their multi-pillar systems and to enable them to support their pension reforms with accurate and trustworthy data. Such a comprehensive overview would enable Member States to design comprehensive pension and social reforms while guaranteeing fiscal sustainability and adequacy and facilitate an objective public debate about reform needs and impacts.
(22) When developing such dashboards, EIOPA suggests using the same indicators as in the triennial Ageing and Pension Adequacy reports, respectively, and in the annual Debt Sustainability Monitor of the European Commission. These indicators would need to be complemented with key information on the contribution of occupational and personal pensions to both adequacy and sustainability. Coverage and accuracy of pension data could be improved over time if the various national authorities involved in the supervision of pension providers collect relevant data and ensure that it feeds into a central data hub. Relevant data would relate to disaggregated information on contributions and accrued claims of both future and current pensioners. Member States could also benefit from exchanging good practices on the prioritisation and collection of data.
(23) Information on factors such as assets, liabilities, contributions, returns and fees, as well as on the gender and age-structure of beneficiaries of supplementary pensions, would increase the accuracy of projections. Member States are encouraged to improve their data on and monitoring of supplementary pensions, and to work with the Commission and other Member States to create a tool that provides a comprehensive overview of the current and future adequacy and sustainability of pension systems. Using the same definitions and classifications as in the Ageing report and the Pension Adequacy report, respectively, would enable the comparability of data made available on Member States’ pension dashboards. The working groups preparing these reports could develop further definitions, assumptions, methodologies, guidance and taxonomies if needed, ensuring that the reporting burden is minimal. In line with the task assigned to the European Commission and Member States by the Eurogroup in inclusive format, the compilation of national pension indicators in an EU pension dashboard would allow Member States to compare their national pension performance with that of other Member States, and take inspiration from good practices leading to high pension adequacy and fiscal sustainability.
(24) Despite the projected decline in pension adequacy should the policy remain unchanged, the low participation in voluntary supplementary pension schemes and the relatively modest amount saved by households in long-term savings and investment products – compared to their financial wealth saved as bank deposits – highlight that existing incentives are not sufficiently compelling to prompt action by many individuals. Auto-enrolment schemes can help in this respect.
(25) Auto-enrolment means that individuals are automatically enrolled into a supplementary pension scheme, with the possibility for them to opt out. It deviates from the opt-in approach that requires an active decision to participate. Auto-enrolment has proven successful in increasing participation in pension savings in countries where it has been implemented. It is typically used for occupational pensions, but it can also be envisaged for other situations, for example for self-employed.
(26) Member States should put the necessary legal framework in place to enable auto-enrolment. To create an enabling environment, they should at a minimum: (i) determine the population eligible to be enrolled automatically; (ii) decide on opt-out and re-enrolment windows; (iii) determine the eligible pension schemes; and (iv) design a default pension plan. Member States would also need to ensure that national competent authorities have the capacity to supervise how auto-enrolment savings are invested and managed, and to ensure that costs remain proportionate to the return offered.
(27) Auto-enrolment mechanisms should be introduced in a way that preserves the integrity of well-functioning national public or supplementary pension schemes. They should not disadvantage participants in existing occupational pension schemes, weaken mandatory participation of workers in occupational schemes where such mandatory participation exists, or undermine the national solidarity mechanisms. Experiences from various countries revealed design features that influence the effectiveness of auto-enrolment. To foster uptake and ensure the success of auto-enrolment, Member States are encouraged to learn from these best practices and adapt them, where necessary, to their country-specific conditions.
(28) To improve pension adequacy and address pension gaps between different population groups, employment sectors and types of employment contract, the population eligible for auto-enrolment should be as broad as possible.
(29) Past experience has shown that auto-enrolment is more effective in increasing participation in supplementary pensions if its implementation allows for sufficient time for information dissemination, a broad consultation of social partners and stakeholders such as financial intermediaries, and for designing effective communication campaigns to inform the public. Synergies with pension tracking systems and financial education and awareness programmes could improve the understanding of prospective members. To ensure learning experiences and reduce adjustment burden, Member States could consider phasing in auto-enrolment in stages, for example, by gradually targeting specific types of employers and eligible people, or by allowing for an increase in contribution rates over time. Starting from a relatively low contribution rate, which gradually increases over time to the level necessary to achieve the pension adequacy target, could also help create acceptance and limit the number of opt-outs, especially in the initial stages of its implementation.
(30) Employers wishing or obliged to initiate auto-enrolment, especially relatively smaller ones, may face administrative and operational challenges in enrolling workers into existing supplementary pension schemes or setting up their own occupational pension schemes. Member States should therefore consider providing employers with administrative support, where appropriate in cooperation with social partners.
(31) For workers, participating in supplementary pensions can imply a reduction in their current disposable income, in exchange for a higher income upon retirement. This may be burdensome, especially for low-wage earners and younger workers, potentially causing higher opt-outs and lower participation rates among these groups. Member States should consider targeted tax incentives, or subsidies, that make it affordable for these groups to participate and remain in auto-enrolment schemes., For these incentives to be effective, they must be underpinned by transparent communication and clear, simple procedures. Member States could also consider more generally to introduce tax incentives to encourage a broad uptake of supplementary pensions, in particular for the groups mentioned above. They are also strongly encouraged to design any tax incentives in a judicious and cost-effective way, taking into account their fiscal implications and their impact on other tools such as savings and investment accounts. Where Member States decide to offer tax and other benefits to encourage the uptake of supplementary pension products, they shall publish detailed information on the impact of tax expenditure on revenues in accordance with their information obligations under Article 14 of Council Directive 2011/85/EU (4), as amended by Council Directive (EU) 2024/1265 (5).
(32) The structure of the job market varies significantly both within and between Member States. Permanent full-time contracts coexist with non-standard contracts and self-employment. The income of people in the latter two employment categories may vary over time and can be subject to frequent interruptions, which means that they may not be well-suited to contributing regularly to a pension scheme. To ensure that all people are given the opportunity to supplement their statutory pensions and can benefit from auto-enrolment mechanisms, Member States should consider granting these two categories special treatment or tailored arrangements, for example greater flexibility on the frequency and amount of their contributions to supplementary pension schemes.
(33) Since not all population groups may consider it convenient or affordable to commit to paying certain contributions into supplementary pensions, they could benefit from opt-out and re-enrolment windows. This would give them the option to exit from, and respectively to re-join, auto-enrolment schemes at a later stage. Having this option would increase acceptance of and trust in the system. Member States could decide on the frequency of those windows with a view to balancing the objective of maximising participation and stability of the system with that of providing people with choices. Member States are recommended to establish clear criteria for eligibility and well-designed opt-out and re-enrolment possibilities.
(34) Some people may lack the information and financial skills necessary for making decisions on long-term investments. They may also find it difficult to choose between different investment profile options, which each provide a different combination of expected return and risk. To avoid overwhelming people with too many and too complex decisions in the auto-enrolment process, Member States should offer default solutions along with limited number of options for elements such as contribution rates, eligible investment plans or products, investment strategies and pay-out arrangements, while ensuring the achievement of adequate retirement income and pension adequacy goals, as experience shows that most workers who are auto-enrolled tend to accept and stick with default offers.
(35) In particular, when having to choose between different investment profiles, given the importance of pension income for social protection, many people would tend to select conservative investment profiles, often with some form of capital protection. However, depending on how it is designed, such capital protection may be expensive and limit the potential upside in the value of pension savings over long investment periods. Life-cycle investment strategies, that change the allocation from riskier to more conservative investments as participants approach retirement provide upside potential while featuring embedded risk-mitigation and can fit most participants’ needs. Member States are recommended to consider these investment strategies as the candidate of choice for default plans. However, participants should also be given the opportunity to choose other options or shift to different investment strategies over their career.
(36) To improve pension adequacy and taking into consideration the different points in time in a person’s career or life when he or she may be enrolled in or have re-opted into supplementary pension schemes people should be given the opportunity to top up minimum contributions with voluntary payments.
(37) The landscape of supplementary pension products and other retirement savings varies significantly across the EU, and it extends beyond occupational pension schemes administered by Institutions for Occupational Retirement Provision (IORPs) that are regulated at EU level. In several Member States workplace retirement plans also take the form of insurance products and personal pension products, and in a few Member States the pan-European personal pension product (PEPP) has been used by some cross-border companies to provide their workers with a retirement plan. All such schemes involve shared contributions by employers and workers. Member States should ensure that any solution chosen as eligible for auto-enrolment can generate benefits for savers in the long term. To this end, it is advisable that Member States select pension products eligible for auto-enrolment based on their potential to meet the desired policy objectives, in consultation with social partners and interested providers where appropriate. Moreover, when granting tax incentives and/or subsidies to employers and workers, Member States should grant the same tax incentives and subsidies for any comparable product. Member States should remove tax and other national barriers to facilitate the cross-border investment and operation of pension funds, thereby promoting greater integration of the EU pension market, to better reflect the single market dimension.
(38) To maximise coverage, default plans should be open to all workers and self-employed, including those working in economic sectors or categories that are not covered by occupational pension schemes established under social partners’ agreements. Workers may change jobs throughout their career, moving between economic sectors or cross-border, or working under different types of contracts that may not be covered by a supplementary pension plan. Member States should consider whether these individuals should continue contributing to the pension plan in which they were previously enrolled, or whether they should enrol in a default pension plan or in any other eligible pension product of choice. In the latter case, Member States should consider whether workers should have the right to move pension entitlements to the new scheme and, if so, under what conditions.
(39) Member States should periodically assess how well the auto-enrolment framework is working and should put in place an adequate supervision mechanism for eligible products or vehicles and their providers. Supervisors should have the capacity to monitor the performance of relevant retirement saving vehicles, and the powers to intervene when necessary and at an early stage to ensure that supplementary pension schemes are effective in improving retirement income and that the rights of participants are preserved over time. Effective supervision can increase trust in the system and reduce opt-outs.
(40) In some countries it has been made mandatory for employers to auto-enrol their workers. Some countries that have introduced this measure have set up a public body that is responsible for administering pension savings and plays a role in the investment of the pension savings. These measures have the potential to significantly boost participation. Member States should assess whether they meet the necessary conditions to implement such measures effectively.
(41) This Recommendation does not affect the competences of Member States to organise and design their national pension systems. This Recommendation does not limit the autonomy of the social partners where they are responsible for establishing and managing pension schemes. Therefore, this Recommendation should not affect national social and labour law on the organisation of pension systems and collective bargaining systems,