Delen van pensioendata: sluit aan bij bestaande initiatieven

The Dutch Federation of Pension Funds supports in its Position Paper the European Commission’s proposal for the Financial Data Access Regulation (FiDA), recognizing the importance of pension data in an individual’s financial situation.
They appreciate the stakeholder-led approach to financial data sharing and argue that it should be tailored to the pension sector’s specific needs while promoting unified data sharing at the sub-sector level. This approach is favored over PSD2’s decentralized method and top-down standard setting, allowing pension data sharing to build upon existing sector initiatives.
They emphasize the need for safeguards to build trust in the open finance framework and protect customers, including compensating data holders, licensing data users, and requiring explicit customer consent.
However, they suggest a few amendments, such as accepting four-monthly updates for pension data, making data holders responsible for data sharing’s functional design, and consulting data users.
Additionally, they express concerns about which pension data should be made available. They recommend excluding data on disability pensions from the scope due to privacy and GDPR concerns and financial exclusion risks.
Regarding survivor pensions, data on family members of pension fund participants should not be made available as they are not considered customers.
The paper argues for a broader scope in the FiDA framework to provide a comprehensive overview of pension entitlements. Currently, the scope is considered too narrow, primarily covering IORPs and PEPP providers. They suggests that the FiDA framework should encompass second and third pillar pension products offered by insurers, particularly life insurance products. While FiDA currently excludes life insurances to prevent financial exclusion, it is argued that the definition of insurance-based investment products in the IDD should be expanded to include pension products as well. This would provide a more comprehensive view of pension data.
Data holders, rather than data users, should be responsible for the functional design of financial data sharing schemes. Responsible data usage is crucial, and customers should have effective control over their data through permission dashboards.
The Federation highlights the need for clearer guidance on the period and purpose of data access to address risks of data leaks and misuse in continued data access rights.