COVIP – Circular on the management of individual pension positions

On January 19, 2024, COVIP (Pension Funds Supervisory Commission) published on its website Circular prot. no. 0000287/24 regarding the unified management of individual pension positions.

With the Circular, the Commission provides guidance to the supervised entities regarding the methods to be adopted to ensure the unified management of individual positions in all cases where multiple positions within the same pension scheme have been allocated to the same subscribing entity.

In accordance with the general principle adopted by the Commission, whereby all payments made during the participation period, related to inbound and outbound operations, constitute a single pension position, the circular requests the pension schemes with multiple positions held by a single person (i) to take initiatives and controls suitable to ensure that each individual holds only one pension position and (ii) to transmit, by May 31, 2024, a report containing the information indicated on the COVIP website.

COVIP emphasizes that a plurality of positions held by the same entity results in increased administrative management costs associated with the application of membership fees for each open position and creates a transparency issue related to the drafting of separate informational documents for each position.