Pension schemes in Ireland should begin work on meeting certain IORP II regulations “immediately”, according to William Fry senior associate, Ciara McLoughlin.

Addressing the Irish Association of Pension Funds (IAPF) DC Conference, McLoughlin urged schemes to start assessing their trustee boards for the required qualifications and experience.

“Can you meet these requirements at present or do you need to go and appoint an additional trustee to ensure you meet these requirements?” she asked.

She also noted that schemes will need to start looking at their policies and procedures to see whether they will fulfil the new IORP II requirements.

“I know from my own experience that some trustees are already doing this and already have some of these procedures in place, but I think it’s time to shake them down and see what needs to be done further,” she continued.

“One of the key policies that needs to be acted on immediately is the remuneration policies. This needs to be in place by 31 December of this year, and the remuneration policy should cover the trustee and staff of the trustee, key function holders, and scheme management where is it outsourced.

“We don’t have any guidance on the content yet, but we presume that the authority will show this to us. This is something that, as a trustee, you might want to begin working on immediately.”

The Irish government completed the transposition of the European Union’s IORP II Directive in April 2021, two years later than the January 2019 deadline.

When asked what they were considering for their schemes due to IORP II, 59 per cent of the sessions’ attendees said they had gap analysis completed and an action plan in place.

Nearly half (44 per cent) were considering a master trust, 32 per cent were thinking of appointing a professional trustee, 28 per cent were relying on a provider to tell them what to do and 25 per cent were considering consolidation.

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