Irish regulator: ‘Considerable consolidation’ likely needed for IORP II

The Irish pensions regulator has published its strategy statement for 2022-24, suggesting “considerable consolidation” of pension schemes would be needed to deal with the requirements stemming from the EU pension fund directive and that it would pay close attention to this.

The transposition of the IORP II Directive, which finally happened in April last year, requires the Pensions Authority to oversee schemes on a forward-looking risk-based supervisory basis, and imposes new and more demanding obligations on many pension scheme trustees.

“In many cases,” the Authority said in its strategy document, “these obligations require a level of complexity and detailed process that is considerably beyond their current practices.

It added: “It will not be practical or economic for many schemes to comply with these new obligations, and the trustees and the sponsoring employer will have to consider multi-employer master trusts or [Personal Retirement Savings Accounts (PRSAs)] as a better means of retirement provision. Neither is it practical for the Authority to apply forward-looking risk-based supervision to tens of thousands of pension schemes.

“It is difficult to see how trustee compliance and forward-looking risk-based supervision can be achieved without considerable consolidation of pension schemes.”

The Pensions Authority said it would review its strategy at the end of 2023 to evaluate progress. A key focus, it said, would be to determine how many schemes had wound up and transferred members and assets to multi-employer schemes or to PRSAs.

“If the numbers of schemes are not reducing significantly, we will have to assess whether a new or revised strategy is required to achieve our objectives.”

In its strategy document, the Pension Authority also noted that the complexity of the demands on scheme trustees was likely to increase with regard to the application of environmental, social and governance factors to trustee investment decisions.

“The volume and sophistication of the information available about these matters is likely to improve, and this will result in increased demands on trustees’ decision processes,” the supervisor said.

“It is also possible that there will be further obligations imposed on trustees in the coming years.”

Concluding comments on its operating context, the supervisor said: “The Authority expects to be more accountable for the work it does, and in turn, will expect those it supervises to be accountable in their turn.”

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