Question ID: 3472
Regulation Reference: (EU) 2019/1238 - Pan-European Personal Pension Product (PEPP)
Topic: Advice (Art. 34 PEPP), Freedom to provide services and freedom of establishment (Art. 14 – 16 PEPP)
Article: N/A
Status: Final
Date of submission: 03 Dec 2025
Question
I would like to inquire whether it is possible to purchase a PEPP (Pan-European Personal Pension Product) in Poland, even though I am currently residing in Germany. I have found information on the EIOPA website stating that PEPP can be purchased from another EU Member State when it is not available in the country of residence. However, I contacted a Polish provider (Finax), and they informed me that the OIPE (European Pension) product is only available to those permanently residing in Poland. I would like to know whether there are any legal or administrative obstacles to purchasing this product in Poland despite not living there.
Background of the question
I am a Polish citizen currently residing in Berlin, Germany. I wish to purchase a PEPP but noticed that this product is not available in Germany. I checked the EIOPA website, which confirms that it is possible to buy PEPP from other EU providers if it is not offered in my country of residence. However, when I contacted Finax in Poland, I was told that the product is only available for residents in Poland, despite me being a Polish citizen.
EIOPA answer
Regulation (EU) 2019/1238 mandates that to provide a product within the territory of a Host Member State under the freedom to provide services or the freedom of establishment, a PEPP provider must open national sub-account that aligns with the specific legal and fiscal requirements of your country of residence (Germany), as established by Article 14. While on EIOPA's website it is indicated that you may purchase a PEPP from a provider in another EU country, that provider is legally required to open a sub-account specifically tailored to your country of residence. Therefore, the Slovak provider (Finax) is legally correct to refuse to sell to you the Polish sub-account (OIPE). The PEPP provider must wait until they launch a compliant German sub-account of their PEPP product to onboard you as a German resident.
Consequently, the only way forward at this stage is either:
- To wait until a provider officially launches a PEPP sub-account compliant with German regulations; or
- To relocate your residence to a Member State where compliant PEPP products are currently offered.
Please note that Article 17 (“The portability service") provides the only derogation allowing contributions to a PEPP sub-account outside of your country of residence. However, this exception is reserved for individuals who were residents of a Member State, opened a PEPP account there, and subsequently moved to another Member State. It does not permit a resident to open a new sub-account in a foreign jurisdiction without a prior history of residence there.