The European Commission (EC) plans to revise the IORP Directive in order to introduce a harmonized framework of quantitative requirements for European pension funds. The so-called 'holistic balance sheet approach' is advised by EIOPA, which enables regulators to compare various pension systems across Europe in one framework. A holistic balance sheet is an extension of the traditional balance sheet, as next to the usual assets and liabilities, conditional assets and liabilities are stated. These conditional assets and liabilities are the economic value of the various policy instruments, which can be valued as embedded options with the help of derivative pricing techniques. The impact of the holistic balance sheet approach is compared to a traditional balance sheet and alternative holistic balance sheet methods are put forward. The holistic balance sheet is intellectually tempting, however it could be further improved. This paper comes up with three concrete proposals in order to improve the proposed holistic balance sheet: an open fund framework instead of a closed one, a dynamic solvency measure instead of a static one, and specific supervision regarding the risk model to be used in the valuation of the holistic balance sheet.

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