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By Dr. Sebastiaan HOOGHIEMSTRA, senior associate in the investment management practice of Loyens Loeff Luxembourg.
Regulation (EU) 2019/1238 (“PEPP 1.0”) was adopted in 2019 and is applicable since 22 March 2022. Till now, the uptake of Pan-European Pension Products (“PEPPs”) is disappointing. For that purpose, the European Commission (“EC”) published on 20 November 2025 a proposal to amend PEPP 1.0 (“PEPP 2.0 Proposal”). This contribution discusses the PEPP 2.0 from a private markets’ perspective.
The PEPP 2.0 Proposal represents the most significant rethinking of the PEPP framework since its introduction in 2019. The proposal removes several of the structural barriers that have prevented the PEPP from...
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