Date: 27th July 2021

BETTER FINANCE welcomes this unique initiative from EIOPA as an example of best practice in terms of supervision and investor protection, not only at the EU level but on the global regulatory scene, especially given the architecture of the distribution market for retail investment products. EU savers have been slowly diverted from direct investments towards packaged, fee-laden products, in particular for sensitive investments, such as retirement provision. BETTER FINANCE shares EIOPA and EIOPA’s members’ concerns over the destruction of value – in real net terms - that occurs with many IBIPs. EIOPA’s attempt to give guidance on value for money is an important step the right direction, but certain elements need to be clarified in how such a concept could be supervised and enforced.