Pan-European Personal Pension Product (PEPP)

Regulation (EU) 2019/1238 of June 20, 2019 creates a European label for individual retirement savings, alongside national products such as the French PER. It has applied since March 22, 2022, once the delegated acts were published. A PEPP can be manufactured by a credit institution, an insurance company, an IORP authorized to provide personal pensions, an investment firm, a UCITS management company or an AIF manager; it is registered with the national authority and then entered in EIOPA's central register. The saver opens one sub-account per member state of residence and keeps the same contract when moving. The offer includes at most six investment options. One of them is mandatory: the Basic PEPP, the default option, which guarantees capital or relies on a risk-mitigation technique aimed at returning it, and whose costs and fees may not exceed, under Article 45(2), 1% of accumulated capital per year. The cap covers management, distribution and the guarantee. For an insurer that must back a capital guarantee over forty years, 1% all-in leaves little room for margin and almost nothing for the distribution network. The market stayed away. In February 2022, fewer than 20% of the 128 respondents to an EIOPA survey were seriously considering offering a PEPP; two years after the date of application, Finax of Slovakia was the only provider selling a PEPP, in four member states, and France's CCSF counted just two registered providers in the EU in 2024. Tax treatment, which stayed national, mattered as much as the cap. On November 20, 2025 (COM(2025) 840), the Commission proposed removing the guarantee and the cap from the Basic PEPP in favor of a value-for-money test; the text is under negotiation.