IORP II – The implications for trustees of Occupational pension plans


If you are operating a Trust based Occupational Pension Plan, you need to familiarise yourself with the rules of IORPS 2. While the transposition remains delayed, we do expect IORPS 2 to be transposed into law in 2021.

In advance of this, the Pensions Authority expects that trustees become familiar with the Directive itself and plan for obvious actions in advance.

The Pensions Authority is expected to adopt a phased transition period for compliance.

The main features include:

  • Active trustee governance with demonstrable planning already taken place
  • Have governance in place for three ‘key functions such as Risk management, Actuarial and internal audit
  • Have documented an effective risk management system
  • A sound remuneration policy
  • Fit and proper persons managing the plan
  • Consider ESG factors
  • Disclosure aspects

We would urge you to speak with your pension consultant to ascertain the impact the impending legislation will have on your company pension structures.