ShareAction welcomes EIOPA's draft advice addressing proportionality, information and duty of care to members and beneficiaries, sustainability, and diversity and inclusion, which represents a first step to ensure IORPs are subjected to similar provisions as other actors in the financial system. Nonetheless, we believe that more ambition is needed to generate meaningful impact, especially with regards to sustainability.

We have provided several suggestions on how to ensure consistency with other legislation, and mainstream sustainability across the different sections of this consultation paper.