If you have a company sponsored pension put in place prior to April 2021, there is one date you cannot afford to ignore: 22nd April 2026.
This is the deadline by which company sponsored pension schemes must either fully comply with the EU’s IORP II (Institutions for Occupational Retirement Provision) directive or have transitioned to an alternative pension structure. With that deadline now almost upon us, the time to act is now.
What Is IORP II and Why Does It Matter to You?
IORP II, the EU Directive on Institutions for Occupational Retirement Provision, was transposed into Irish law back in April 2021. Its purpose is straightforward: to ensure occupational pension schemes are soundly governed and that members’ benefits are properly protected.
For years, single-member schemes like Executive Pensions operated under an exemption. That exemption is now gone. From 22nd April, all occupational pension schemes, regardless of size, must comply.
What does full compliance actually mean in practice? According to the Standard Life guide to IORP II, it involves a significant increase in governance and trustee responsibilities, including:
Changes to how scheme information is disclosed and who can access it
Appointing key function holders with specialist skills in risk management and internal audit, as well as having a qualified trustee
Clear written policies for the scheme
A risk assessment process with ongoing monitoring, reporting, and an annual compliance statement
Annual audited accounts, which must be signed off by an auditor and made available within eight months of the scheme year end
These are not light-touch requirements. They represent a substantial administrative and financial burden, one that many SSAPS holders will find simply unworkable.
The Cost of Doing Nothing
The financial consequences of non-compliance are real and serious.
Staying put and attempting to run an IORP II-compliant single-member scheme could cost you upwards of €5,000 per year in fees, and for some schemes, annual costs have reportedly reached five figures. Industry experts have noted that this makes full compliance uneconomical for the vast majority of Executive Pension holders, with few providers willing to offer such products under the new regime.
There are legal consequences too. The Pensions Authority monitors compliance with all provisions of the Pensions Act. Those found guilty of an offence can face fines of up to €25,000, or even imprisonment for up to two years.
And there is a more immediate risk: if you fail to engage, your trustee may resign. This leaves your pension in limbo and creates a far bigger problem than taking action now would have.
What Are Your Options?
The good news is that there are several well-established alternatives available to Executive Pension SSAPS holders. Depending on your circumstances, you might consider:
A Buyout Bond (BOB): A straightforward transfer option for those who are no longer contributing to their scheme, accessible from age 60.
A Non-Standard PRSA: For those still actively contributing, non-standard PRSAs offer considerable flexibility in asset selection and allow ongoing employer contributions (subject to current limits of 100% of earnings following the January 2025 rule change).
A Master Trust: Brings multiple schemes together under the new regulatory framework. Can offer similar funding levels to older occupational schemes, though with a greater focus on regulated investment markets.
An Approved Retirement Fund (ARF): For those who are ready to retire their pension entirely and begin drawing down their fund.
In some cases, a combination of structures, splitting the pension pot across two vehicles, may actually serve you better than any single option alone.
Don’t Let Inertia Cost You
It is estimated that as many as 90,000 single-member executive schemes were still in operation as recently as September 2025. If you are one of those holders who has yet to act, the window is closing fast.
Moving a pension is not always simple. Complicated investment structures, pension adjustment orders, and the need for proper financial advice all mean that the process takes time. Starting late makes an already involved process even more stressful.
Talk to Riordan Financial Today
At Riordan Financial, we have helped clients navigate exactly this kind of change. Whether you need clarity on what IORP II means for your specific scheme, guidance on which alternative structure best suits your circumstances, or hands-on support through the transition process, we are here to help.
The April deadline is close. Don’t leave this to chance.
Get in touch with the team at Riordan Financial today for a no-obligation conversation about your options. A short call now could save you significant costs, stress, and uncertainty down the line.