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IAPF expresses concern over Government’s delay in publishing IORP II pension legislation to meet Jan 2019 EU deadline

07/10/2018 Posted by IAPF | Comments(0)

The Irish Pensions system is set for major change over the coming months and years, with consultation papers issued recently on the State Pension, Reform and Simplification of the private pension system, Master Trusts and the Auto-enrolment Strawman. In addition to this, a new European Pensions Directive needs to be transposed into Irish law by next January and schemes will be required to report on assets and liabilities to the ECB and EIOPA. This were the topics discussed at the IAPF Annual Benefits Conference on Tuesday the 2nd of October at the Convention Centre Dublin, sponsored by J.P. Morgan Asset Management. The Conference was attended by 300 delegates.

The IAPF took the opportunity to express its grave disquiet at the failure of the Government to publish draft legislation implementing the provisions of the EU’s Institutions for Occupational Retirement Provision (IORP II) Directive. The representative body contends that with just three months to go before the new European pension requirements are due to come into force, the failure to publish the draft implementing legislation will not allow for consultation and feedback and will make it difficult for schemes to comply with their obligations.

Speaking to attendees, Peter Fahy, Chairperson of the IAPF, “The provisions of IORP II are to be transposed into Irish law by 13th January 2019 the failure to publish the implementing legislation is quite simply unacceptable and undermines a lot of good work that Government departments are doing in other areas of pensions reform”.

IORP II will introduce new governance and disclosure requirements for occupational pension plans within the EU.

At this point in time it is unclear which schemes the new requirements will apply to as the Directive allows for an exemption for schemes of less than 100 members which has been availed of under the 1st Pensions Directive.

The Directive also allows for it to be implemented in a way that takes account of the size, complexity and scale of the activities of the pension scheme.

The IAPF say that the information provided to members on an annual basis and on joining a scheme needs to change but that those changes cannot be made until the legislation is clear.

Other highlights from the new Directive included :

  • The requirements relating to the content and format of Pension Benefit Statements to be issued annually to members have will have to include projections on a number of different bases.
  • These will also have to be issued to people who have left the employer but still have benefits in the scheme.
  • Statements may be issued in electronic format and be presented in a way that is easy to read. The statement should include a best estimate and an unfavourable scenario.
  • The whole governance structures of pension schemes will change with trustee board having to have qualified and experienced trustees.
  • Schemes will have to have key function holders including internal audit functions


About the IAPF Established in 1973, the Irish Association of Pension Funds (IAPF) is a non-profit, non-commercial organisation representing pension savers whose aim is to ensure we have a secure, fair and simple system of pension provision in Ireland.



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