EFAMA believes that IORPs should be able to invest in financial instruments traded in all third country markets where the latter meet certain conditions, regardless of the adoption of an equivalence decision by the Commission (...).

On Sustainability: (...) EFAMA agrees that IORPs should consider ESG risks if they want to acquire a holistic view of their exposure to overall risks, in particular because of the long-term investment horizon of IORPs. This view is consistent with the prudent person principle and the requirement that IORPs must ensure safety, quality, liquidity and profitability of the portfolio as a whole.