FECIF Editorial

As 2026 approaches, the European Union faces an exceptionally dense policy agenda in financial services. In the final weeks of 2025, the European Commission unveiled several initiatives under the umbrella of the Savings and Investments Union (SIU), spanning pensions, capital markets integration and sustainable finance. Together, these measures will shape much of the regulatory debate and implementation work over the coming year.

On 20 November, the Commission presented a package aimed at improving access to supplementary pensions, responding to demographic pressures and increasingly fragmented career paths. The objective is clear: to strengthen retirement outcomes by encouraging occupational and personal pension savings alongside public systems. However, while the direction is understandable, the proposed tools raise important questions about effectiveness and proportionality.

The Recommendation on auto-enrolment, pension tracking systems and national dashboards reflects a strong belief in structural solutions to boost participation. Automatic enrolment with opt-out options has proven successful in some Member States, yet its broader application risks overlooking national specificities, labour market structures and existing pension cultures. Likewise, pension dashboards may improve transparency, but they also introduce new layers of governance and data management, with uncertain added value for savers if not designed in a truly user-friendly manner. There is a fine line between empowering citizens and adding further complexity to already intricate pension systems.

The legislative proposals reinforce this cautious reading. The revision of the IORP II Directive aims to modernise occupational pensions by fostering consolidation, diversification and scale. While these goals are legitimate, further regulatory refinement may not, on its own, address the structural barriers limiting coverage and participation across Member States. Similarly, the proposed reform of the PEPP Regulation, introducing a “Basic PEPP” without advice alongside more tailored options, raises concerns about whether simplification alone can revive a product that has so far seen limited market uptake. The risk is that regulatory redesign substitutes for a deeper reflection on demand, incentives and the indispensable role of advice.

Indeed, across the pensions agenda, the role of financial intermediaries and advisers remains pivotal. Effective retirement planning cannot rely solely on standardised products or automated mechanisms. Particularly for older citizens and those with non-linear careers, personalised guidance is essential to ensure informed decisions and adequate protection. Any attempt to broaden access to pensions should therefore avoid marginalising advice in the name of cost reduction or formal simplicity.

Just a few weeks later, on 4 December, the Commission adopted the Market Integration Package, another core pillar of the SIU. This set of measures seeks to remove barriers within the single market for financial services, simplify regulation and supervision, and support innovation. Proposals such as enhanced passporting, the creation of a pan-European market operator (PEMO), and greater supervisory convergence under ESMA reflect a long-standing ambition to achieve genuine economies of scale across borders. Here, the emphasis on simplification and consistency is welcome, provided it translates into tangible relief from regulatory fragmentation rather than a mere reallocation of complexity at EU level.

The SIU narrative ties these initiatives together, presenting them as mutually reinforcing steps towards deeper capital markets and greater citizen participation. Yet the success of the SIU will ultimately depend on delivery. Coordination across different files is essential, but so is restraint. An accumulation of well-intended reforms risks becoming counterproductive if it overwhelms market participants and end-users alike.

Sustainable finance reforms complete this already crowded agenda. Also on 20 November, the Commission proposed a revision of the Sustainable Finance Disclosure Regulation (SFDR), aiming to simplify disclosures, reduce compliance costs and introduce a clearer product categorisation. The move towards fewer, more meaningful disclosures and a three-tier classification system is a step in the right direction. Still, the challenge will be to ensure that simplification genuinely improves investor understanding rather than shifting uncertainty to new definitions and thresholds.

In this context, 2026 will be less about launching new strategies and more about testing the credibility of existing ones. The roll-out of SIU initiatives will require careful legislative scrutiny, realistic implementation timelines and a constant focus on market realities. Policymakers will need to resist the temptation to equate additional rules with better outcomes.

A busy calendar can be a sign of political momentum. It can also be a warning signal. If the SIU is to deliver on its promise of stronger retirement security, deeper markets and more sustainable investment, 2026 must prioritise pragmatism over prescription, proportionality over ambition on paper, and trust in intermediaries over overly standardised solutions. Only then can reform translate into real benefits for European savers and investors.