Your IORP II Obligations
IORP II (the EU Institutions for Occupational Retirement Provision Directive) was transposed into Irish law in 2021. It significantly raised the governance bar for trustees of occupational pension schemes.
This page gives you a plain-language summary of your core obligations and maps each one to the relevant PensionPortal.ai feature.
Obligation Summary
| Obligation | What it means | Platform feature | Deadline / Frequency |
|---|
| Annual Compliance Statement | File a signed statement confirming compliance with 20 regulatory requirements | ACS Wizard | 31 January each year |
| Own-Risk Assessment | Document and assess all material risks facing the scheme | ORA Tool | Every 3 years (or after significant change) |
| Key Function Holders | Appoint qualified persons to Risk, Internal Audit, and Actuarial functions | KFH Manager | Ongoing; notify PA within 30 days of appointment |
| 11 Written Policies | Adopt and maintain mandatory written policies | Policy Library | Every 3 years review; adopt through platform |
| Fit & Proper Assessment | Assess trustees and KFHs against fit & proper criteria | Fit & Proper module | Before appointment; reviewed annually |
| Investment Policy Statement | Document your scheme’s investment strategy | Policy Library | Review every 3 years |
| Remuneration Policy | Policy on pay structures that don’t incentivise excessive risk | Policy Library | Review every 3 years |
| DORA Compliance | Digital Operational Resilience Act — ICT risk management | DORA Policy + mapping | Review annually |
| OMA Transition (if applicable) | One-member arrangements must comply or transfer to master trust | OMA Triage Tool | April 2026 deadline |
What You Must Do — Key Obligations in Detail
1. Annual Compliance Statement (ACS)
The ACS is a formal declaration, signed by at least two trustees, confirming that the scheme complies with its legal obligations. It covers 20 areas of governance, investment, and operational compliance.
You must file this every year. The deadline is 31 January.
→ How to complete your ACS
2. Own-Risk Assessment (ORA)
The ORA is a written document that identifies, assesses, and documents all material risks facing the scheme. It must cover 8 risk categories defined by the Pensions Authority.
Required at least every 3 years, and whenever a significant change occurs (e.g., change of investment strategy, major membership change, significant market event).
→ How to complete your ORA
3. Key Function Holders (KFHs)
IORP II requires schemes to have three key functions:
- Risk Management — oversees the scheme’s risk framework
- Internal Audit — provides independent assurance on governance and controls
- Actuarial — advises on funding, liabilities, and investment strategy
Each KFH must be fit and proper. Appointments (and removals) must be notified to the Pensions Authority within 30 days.
→ Managing your Key Function Holders
4. 11 Mandatory Written Policies
The Pensions Authority requires trustees to have 11 written policies in place, reviewed at least every 3 years.
→ Your 11 Mandatory Written Policies
5. OMA Transition (if applicable)
If your scheme is a one-member arrangement (a scheme with a single member, typically a company director), you face an April 2026 deadline to either comply with full IORP II requirements or transfer to a master trust structure.
→ The April 2026 OMA Deadline
Key Dates and Deadlines
| Date | Obligation |
|---|
| 31 January (annual) | Annual Compliance Statement filing deadline |
| Within 30 days of appointment | Notify PA of new Key Function Holder |
| Every 3 years | Own-Risk Assessment review |
| Every 3 years | Written Policies review cycle |
| April 2026 | OMA Transition deadline (one-member arrangements only) |
What Happens If You Don’t Comply
The Pensions Authority has significant enforcement powers under the Pensions Act:
PA Enforcement Actions include:
- Formal investigation of the scheme and individual trustees
- Direction to remedy non-compliance (with a fixed deadline)
- Appointment of an inspector
- Referral to the Financial Services and Pensions Ombudsman
- In serious cases: disqualification of trustees and/or winding up of the scheme
Non-compliance is not just a reputational risk — it has direct legal and financial consequences for trustees personally. The best defence against PA enforcement is a documented compliance posture. PensionPortal.ai creates a time-stamped record of every compliance action you take — giving you evidence that you’ve been actively managing your obligations.
