Irish Pensions Authority publishes details on timings for ORA and ACS

Ireland’s Pensions Authority has published information for trustees on the timing of the own-risk assessment (ORA) and the form of the 2021 annual compliance statement (ACS) provided for under the Pensions Act, 1990, as amended (the Act).

Section 64AL of the Act requires trustees to carry out and document an ORA at least once every three years, and without delay following any significant change to the risk profile of the scheme or trust RAC.

The authority said that except for one-member arrangements established before 22 April 2021, the latest date by which a scheme's initial ORA can be completed is 22 April 2024. However, it advises trustees to prepare their initial ORA at an earlier date in order to gain a comprehensive picture of their scheme’s risk profile and what consequent actions may be required to mitigate identified risks.

In particular, the authority said trustees of defined benefit schemes should align the preparation of the ORA with the scheme’s triennial actuarial valuation. Trustees of master trusts should carry out and document an ORA by July 2022 in accordance with the authority’s current compliance timeline.

“Trustees should also consider, in conjunction with the risk management key function holder, potential significant changes to the risk profile of the scheme that may trigger the preparation of a new ORA. The authority may request trustees to furnish it with the ORA and/or any other documentation considered necessary as part of its ongoing supervisory activity,” it stated.

In regards to the ACS, information on the ACS can be found in the authority’s news alert dated 2 September. The ACS form includes references to the Code of Practice for trustees that will be published the week commencing 15 November 2021. Trustees should also be prepared that more detailed information will be required in the ACS form in future years and the authority will provide further details on this in due course.

Over the coming weeks, the authority is set to publish several pieces of information, including the final Code of Practice during the week commencing 15 November 2021, guidance for one-member arrangements (OMAs) during the week commencing 15 November 2021, instructions on outsourcing notification on 1 December 2021, guidance for the public and employers about the minimum standards they should expect from master trust vehicles during the week commencing 13 December 2021, and a findings report from the authority’s engagements with master trust, DB and DC schemes during the week commencing 13 December 2021.

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