Supervisory Review Process (SRP)
The Pensions Authority’s Supervisory Review Process (SRP) is the structured mechanism through which it assesses the governance and compliance of Irish pension schemes. Introduced as a core element of the PA’s Supervision 2025–2029 strategy, the SRP provides a consistent, repeatable framework for supervisory engagement — replacing the previous ad-hoc desk review model with a structured, evidence-driven assessment.The Six Pillars
The SRP is structured around six pillars. For each pillar, the Pensions Authority assesses whether the trustee board has adequate governance arrangements in place and whether those arrangements are operating effectively in practice.| Pillar | What the PA Assesses |
|---|---|
| 1. Governance | Quality of policies, board meeting practice, KFH oversight, decision-making records |
| 2. Operations | Administration standards, member data accuracy, contribution processing, service provider oversight |
| 3. Risk Management | ORA quality, risk appetite statements, risk register currency, trigger-event response |
| 4. Communications | Member disclosure standards, benefit statement accuracy, material change notices |
| 5. Investment | Investment Policy Statement quality, investment monitoring, cost transparency, manager oversight |
| 6. Fees & Charges | Total cost disclosure, value for money evidence, benchmarking against alternatives |
The PA does not assess each pillar in isolation. Weaknesses in one pillar — for example, poor ORA quality — will inform its view of the overall governance standard of the scheme. A strong investment framework will not offset inadequate risk governance.
Pillar Breakdown
Pillar 1: Governance
Pillar 1: Governance
What the PA looks for:
- A current, board-approved set of 11 written policies — reviewed and genuinely applied, not just adopted
- Board meeting minutes that record substantive discussion, not just formal approval of agenda items
- Evidence that all four Key Function Holders are appointed, notified to the PA, and reporting to the board
- Conflict of interest declarations maintained and current for all trustees and KFHs
- Trustee fit and proper assessments on file
- Version-controlled policy registry with adoption dates, review history, and next review dates
- Board minutes stored with timestamps
- KFH registry with appointment records, fit and proper assessments, and PA notification confirmations
- COI register with annual declaration status
Pillar 2: Operations
Pillar 2: Operations
What the PA looks for:
- Accurate and complete member records (names, addresses, PPS numbers, contribution history)
- Reconciled contribution records — payments matched to member accounts
- Evidence that the scheme’s administrator is performing to contracted standards
- Outsourcing register covering all service providers with written agreements in place
- Data protection governance (DPA with data processors, GDPR compliance measures)
- Member records with data quality validation
- Contribution reconciliation workflow
- Outsourcing register with provider details, SLA summaries, and PA notification status
- Audit log of all data access and changes
Pillar 3: Risk Management
Pillar 3: Risk Management
What the PA looks for:
- A completed Own Risk Assessment that is scheme-specific, current, and board-owned
- Risk appetite statements that confirm whether each risk area sits within or outside tolerance
- Evidence the ORA was discussed and approved at a board meeting (not just circulated for signature)
- Trigger-event reviews when circumstances change
- Outsourcing and DORA/ICT risks addressed within the ORA
- ORA with per-category risk appetite statement, tolerance thresholds, and current status (Within / Approaching / Outside)
- 32-entry risk library pre-seeded with IORP II reference risks across 8 categories
- Alert system flagging risks outside or approaching tolerance
- ORA version history with board approval dates
Pillar 4: Communications
Pillar 4: Communications
What the PA looks for:
- Annual benefit statements issued to all active and deferred members within the required timeframe
- Material change notices issued when required (scheme amendments, wind-up notices, significant investment changes)
- Evidence of adequate member communication channels
- ACS submitted where required (DB schemes)
- Benefit statement generation and delivery tracking
- Compliance calendar with communication deadlines
- ACS wizard with submission tracking
Pillar 5: Investment
Pillar 5: Investment
What the PA looks for:
- A current Investment Policy Statement that reflects actual investment strategy — not generic template language
- Evidence of regular investment performance monitoring against the IPS objectives
- Cost transparency — trustees must know what they are paying for investment management
- Evidence that the trustee board actively oversees the investment manager, not passively delegates
- Investment Policy document in the Policy Registry with adoption and review dates
- VFM Dashboard with cost analysis and benchmarking
- Board minutes recording investment review discussions
Pillar 6: Fees & Charges
Pillar 6: Fees & Charges
What the PA looks for:
- Evidence that trustees have actively assessed whether scheme costs represent value for money for members
- Benchmarking of scheme costs against comparable alternatives (master trusts, DC consolidation vehicles)
- Disclosure of total costs to members (in line with the Cost Transparency Standard where applicable)
- Link between cost governance and member outcome metrics
- VFM Dashboard: sortable provider contracts, Current Scheme vs Master Trust benchmarking, member impact calculations (cost per member, cost ratio, 10-year fee drag)
- VFM RAG summary card with evidence for board minutes
How PensionPortal.ai Maps to the SRP
| SRP Pillar | Platform Feature | Evidence Generated |
|---|---|---|
| Governance | Policy Registry, KFH Registry, COI Register, Board Minutes | Policy adoption records, KFH appointment docs, COI declarations |
| Operations | Member Management, Outsourcing Register, Data Quality | Member records, contribution reconciliation, outsourcing register |
| Risk Management | Own Risk Assessment (with appetite/tolerance), Risk Library | ORA with board sign-off, risk tolerance status, risk library entries |
| Communications | ACS Wizard, Compliance Calendar, Benefit Statements | ACS records, communication deadlines, statement delivery |
| Investment | Policy Registry (IPS), VFM Dashboard | IPS adoption, investment monitoring records |
| Fees & Charges | VFM Dashboard | Cost benchmarking, member impact, VFM RAG status |
SRP Evidence Pack Module
PensionPortal.ai includes a dedicated SRP Evidence Pack module to help trustees prepare for regulatory engagement.Open the SRP Evidence Pack
Navigate to Schemes → [Your Scheme] → SRP Evidence Pack. You will see a card grid with one card per SRP pillar showing the current completion status.
Work through each pillar
Click any pillar card to open the assessment detail. For each pillar, you can:
- Add evidence notes describing the governance in place
- Upload or link to supporting documents
- Log any PA findings received and assign remediation actions
Progress the status
Each pillar moves through Draft → In Progress → Submitted as you build out the evidence. The overview card updates automatically.
Track findings to closure
If the Pensions Authority issues findings following a review, log them in the findings tracker. Assign a responsible person, set a target date, and mark findings as closed when remediation is complete.
Preparing for a PA Review
Trustees who maintain continuous SRP readiness will respond to any PA engagement quickly and confidently. The following items should be in place at all times:Governance — always ready
Governance — always ready
- All 11 written policies current (reviewed within last 3 years)
- Board minutes for at least the last 12 months showing substantive discussion
- KFH appointments and PA notifications complete and current
- COI declarations up to date for all trustees and KFHs
Risk Management — always ready
Risk Management — always ready
- ORA completed within the last 3 years (or since last trigger event)
- Risk appetite statement and per-category tolerance status populated
- ORA formally presented and signed by the board
- Any risks Outside tolerance have documented remediation actions
Operations — always ready
Operations — always ready
- Member records validated (no outstanding data quality exceptions)
- Contribution records reconciled and current
- Outsourcing register up to date with written agreements confirmed
Investment + Fees — always ready
Investment + Fees — always ready
- IPS current and board-approved
- VFM assessment completed and on file
- VFM Summary Card at Amber or Green (Red requires board action)