The NAPF said the UK was not being given enough time to consider the EC's proposed approach to estimating the impact of a Solvency II-type regime for final salary pensions.
It also criticised the omission of key questions from the study, and the unexpected introduction of complicated new issues.
The NAPF made these points in its response to the Quantitative Impact Study (QIS) consultation from the European Insurance and Occupational Pensions Authority (EIOPA). The consultation sought views on how EIOPA should measure the impact of Solvency II-type rules on pension funds.
Darren Philp, NAPF policy pirector, said: "It is astonishing that the industry has been given only six weeks to assess very complex and technical issues, which will help determine the future of pension provision in the UK.
"Solvency II-type proposals could have extremely damaging consequences for our pensions and the wider economy. They would hit businesses running final salary pensions, and would also take jobs and investment out of the UK's faltering economy.
"We are concerned that the quality of policy-making is being driven by the political timetable, rather than by a commitment to getting it right. These are long-term issues and the EC should take the time to address them properly, rather than rushing them through.
"Crucially, the consultation does not answer the key question of how the Holistic Balance Sheet will be used in practice. Will it form a new funding regime, or will it simply be a disclosure item for trustees?
"The consultation also throws up completely new concepts, such as the question of how to value pension protection schemes and employer support for a pension scheme. These issues deserve their own round of QIS."
The NAPF calculated that Solvency II-type rules could cost UK pension funds at least an extra £300bn as they would be forced to dramatically increase the capital in the fund. Faced with extra funding demands, many companies would have no choice other than to close their final salary pension schemes.
Jane Beverley, head of research at consultancy Punter Southall, added: "We are very concerned at the limited scope and timescale for the QIS. Applying a holistic balance sheet based on Solvency II to defined benefit pension schemes could have massive consequences - for the pension schemes themselves, their members, and the employers who sponsor those schemes, as well as for the European economy as a whole. These are issues that demand careful and considered scrutiny, not a six-week consultation.
"Insurers have had five QISs to refine how Solvency II should apply to them in practice. It seems bizarre that the European Commission should propose only one QIS for pensions (and that after only a six-week consultation), when many of the elements of the holistic balance sheet that are unique to pension schemes (such as the valuation of the sponsor covenant and assessment of the value of the Pension Protection Fund) have only just been put forward for discussion for the first time.
"Overall, the QIS will fail to do what it says on the tin, i.e. to quantify the impact on pension schemes, because it will not cover the actual implications if the holistic balance sheet does not balance - will employers have to fund the gap, and, if so, over what time period? All this QIS can do is to produce some meaningless numbers that will inform no-one about the real impact that a Solvency II style regime could have on pensions."
