The April 2026 OMA Deadline
What is a One-Member Arrangement?
A one-member arrangement (OMA) is an occupational pension scheme with a single member — typically a company director or senior executive who has set up a personal pension scheme within their company. OMAs are common in Ireland, particularly among owner-directors and professional service firms. Until recently, they operated under a lighter regulatory regime. That is changing.The Deadline
Under the IORP II Regulations and the Pensions Authority’s transition programme, one-member arrangements must come into full IORP II compliance by April 2026. This is a significant regulatory change. Full IORP II compliance for an OMA means:- Appointing three Key Function Holders (Risk, Internal Audit, Actuarial)
- Completing an Own-Risk Assessment
- Adopting all 11 mandatory written policies
- Filing an Annual Compliance Statement
- Meeting all other governance requirements
Your Two Options
Option 1: Full IORP II Compliance
Bring the OMA into full compliance with IORP II by April 2026. This means appointing KFHs, completing the ORA, adopting policies, and filing the ACS.Best for: Larger OMAs where the benefit of maintaining the scheme as a standalone structure outweighs the governance cost. Typically schemes with significant assets.
Option 2: Transfer to a Master Trust
Transfer the OMA’s assets to a master trust arrangement, which handles all IORP II governance on behalf of members.Best for: Smaller OMAs where the cost and complexity of full compliance is disproportionate. The member retains their pension savings — only the governance structure changes.
Timeline
| Date | Milestone |
|---|---|
| Now | Use the OMA Triage Tool to assess your options |
| Q1 2026 | Make your decision: comply or transfer |
| Q1–Q2 2026 | If transferring: initiate transfer process with master trust provider |
| April 2026 | Deadline — scheme must be compliant or transfer must be complete |
| After April 2026 | PA begins enforcement for non-compliant OMAs |
The 4-Stage OMA Transition Pathway
PensionPortal.ai’s OMA module guides trustees through the full transition with a 4-stage pathway tracker. Navigate to Schemes → [Your Scheme] → OMA Triage to start or resume your pathway. The live deadline countdown banner is colour-coded using the platform’s urgency system: green when time is ample, amber as April 2026 approaches, and red within 72 hours of the deadline.Stage 1: Assessment — Run the OMA Triage Tool
Answer questions about your scheme (assets, member age, employer contribution status, current governance) and the tool will calculate the estimated annual cost of IORP II compliance, identify available master trust options, produce a cost-benefit comparison, and recommend a path with supporting rationale.
Stage 2: Decision — Record the trustee decision
Record your formal decision in the platform — including the options considered, the rationale for the chosen path, and any professional advice obtained. This decision record is evidence for the PA that the trustee board made an informed, documented choice.
Stage 3: Action — Implement the chosen path
If complying: the platform creates a compliance action plan covering KFH appointments, ORA, policies, and ACS. If transferring: the platform guides you through transfer documentation. Track milestone completion against the April 2026 deadline.
Stage 4: Transition — Complete and evidence
Confirm completion of the transition — whether that is achieving full IORP II compliance or completing the transfer to a master trust. The platform generates a transition evidence summary that can be submitted to the PA to confirm the OMA derogation has been addressed.
The Triage Tool uses publicly available information about master trust providers. It does not constitute financial advice. Always obtain independent professional advice before making a transfer decision.
Consolidation as a Pathway
For many OMAs, wind-up and transfer to a master trust or DC consolidation vehicle is the right outcome — not because full IORP II compliance is impossible, but because the governance cost is disproportionate to the scheme’s size. What to prepare if consolidating:- Member consent: Transfer to a master trust requires member consent. Document that the member has been provided with adequate information about the receiving scheme (charges, investment options, governance).
- Transfer value: Obtain an accurate transfer value from the current administrator. For insured arrangements, request surrender values and check whether market value reductions apply.
- Scheme accounts: Ensure the scheme’s annual accounts are up to date before wind-up. Outstanding contributions should be collected and reconciled.
- Wind-up notification: The Pensions Authority must be notified of the scheme wind-up. PensionPortal.ai generates the standard wind-up notification template.
- Revenue Commissioners: The scheme’s Revenue approval may need to be formally surrendered. Your pension adviser should confirm the process.
Scheme Authorisation Requirements
The PA is working with the Department of Social Protection on a scheme authorisation framework for schemes that wish to continue as authorised IORP II structures. Trustees of schemes considering remaining as standalone structures should be aware:- The PA is in direct contact with scheme administrators regarding OMA compliance status
- Issues should be raised with your adviser and documented in the platform well in advance of April 2026 — leaving issues unresolved until March or April 2026 significantly reduces your options
- Trustees who have demonstrated a documented, diligent transition process are treated differently from those who have taken no action
How the OMA Triage Tool Works
The Triage Tool asks about:- Scheme asset value
- Member’s age and proximity to retirement
- Employer contribution status (active or deferred)
- Current governance arrangements
- Member’s preference (retain standalone scheme vs. simplify)
- Calculates the estimated annual cost of IORP II compliance for your scheme
- Identifies available master trust providers and their typical transfer costs
- Produces a cost-benefit comparison
- Recommends a path with supporting rationale