by Stephen Gillick, Partner in the Employment Law and Benefits team at Mason, Hayes & Curran LLP
The Pensions Authority hosted their Supervision of Pensions 2025-2029 conference on 17 September 2025 in Dublin’s Mansion House. The conference focused on a series of topics including:
- Pension scheme consolidation
- The Authority’s continued implementation of forward-looking, risk-based supervision
- The growing impact of EU regulatory obligations, and
- The increased importance of high-quality data to support supervisory efforts
The following are the main key takeaways:
Pension scheme consolidation
The Authority is encouraging the consolidation of pension schemes, especially for one‑member and small Defined Contribution (DC) schemes. This development is in light of the exemption from the provisions of IORP II for one‑member schemes, or ‘OMAs’, expiring in April 2026. Recent statistics show that there has already been an uptake in moving to consolidation:
- 48% reduction in the number of Group DC schemes between Jan 2023 and Sept 2025
- 36% reduction in OMAs between January 2023 and September 2025
While this is a positive move, the Authority recognises that there will be some slow adapters and will consider whether enforcement actions are appropriate for non-compliance once the exemption expires in April 2026.
Master trusts
There are currently 17 master trusts established in Ireland – 12 of these are group scheme arrangements and 5 are retail for OMAs. Master trusts are playing a bigger role in pension scheme consolidation in Ireland. Between June 2023 and June 2025, assets under management rose from €13.9 billion to €35.2 billion, while the number of participating employers increased from 15,000 to 30,000.
However, with such a sharp increase, questions around market saturation, market protection and governance are also increasing. The Minister for Social Protection indicated earlier this year that legislation for enhanced legal underpinning for master trusts is on the way. The Minister stated that this is likely to involve introducing obligations on master trust trustees over and above those required of single employer schemes, to support sound management and protect the rights of members.
Legal implications of EU regulation
Compliance with EU directives such as IORP II, the Digital Operational Resilience Act (DORA) and the Sustainable Finance Disclosure Regulation (SFDR) will increasingly shape pension scheme obligations. This is particularly the case concerning data security and sustainability. European developments are increasingly applied to all financial institutions including the pensions sector. Consequently, pension scheme trustees are under increasing pressure to ensure that pension management and administration systems are compliant and fit for purpose. Additionally, trustees will be required to provide considerably more data to the Authority. Details relating to this will be published before the end of the year.
Review of IORP II and PEPP
The European Commission has commenced its review of IORP II and the Pan-European Personal Pension Product (PEPP) regulations following an eight-week review of certain aspects of the regulations which commenced in June 2025. The insights gathered from this consultation should inform a package of measures that will be presented during Q4 2025.
Pension scheme authorisation
Legislation is on the way for a new pension scheme authorisation process. It is important to note that schemes which already have approval will also need to be authorised within the new system. Despite the added administrative step, this new process will be positive change and will enable a more flexible and responsive system of supervision that can respond to developments in the pensions sector.
Pensions Authority consultation
Defined Benefits scheme (DB scheme) consolidation
The Authority recently undertook a consultation on the DB scheme consolidation. An initial analysis shows that from the 11 submissions received, opinions were mixed on the prospect.
Among the potential benefits identified are reduced employer costs on governance and investment management. However, it also identified potential risks including lack of demand, lack of scale and efficiencies, and lack of competition.
A full analysis of the responses is continuing with long term plans and other options for DB schemes also under consideration. However, clear and strong rationale are required to justify any future legislative amendments.
“In-scheme” drawdowns and Personal Retirement Savings Accounts (PRSA) investment rules
Upcoming consultations by the Authority can be expected on “in-scheme” drawdowns and PRSA investment rules. The backdrop to these consulations lies in a Government mandate for the Interdepartmental Pensions Reform and Taxation Group (IDPRTG) to review Approved Retirement Funds and the potential introduction of an “in-scheme” drawdown option.
Personal Retirement Savings Account (PRSA)
The increased use of non-standard PRSAs is a reversal of the standard/non-standard pattern and is an emerging trend in Ireland with 66% of savings in non-standard PRSAs. The assets held in PRSAs have increased from €9 billion in Q1 2023 to €20 billion in Q2 2025, demonstrating consumer confidence in this form of retirement planning. A public consultation on PRSAs is expected by the end of 2025.
Data quality and reporting
Accurate and timely data will be critical for compliance and regulatory assessments, with poor data potentially leading to enforcement actions. Increasingly, the Authority and the Central Bank are working more closely with a view to enhancing their collective roles through the exchange of experience and insights. Therefore, trustees must prepare for more rigorous data requirements and validation checks in the future.
What is coming down the tracks?
- A new scheme authorisation process
- Legislation to provide for enhanced legal underpinning of master trust regimes in Ireland
- More EU legislation and requirements, i.e. DORA, ESAP, and the review of IORP and PEPP
- Upcoming consultations on in-scheme drawdowns and PRSA investment rules, and
- A continuing focus by the Authority on its supervisory role
Finally, the Pensions Authority acknowledged the valuable role trustees and, in particular, lay trustees play within the industry. Trustees generally act in good faith, however, this is no longer sufficient. Trustee boards now must collectively have the skillset, qualifications and expertise to deliver high quality pension scheme governance and regulatory compliance. The Pensions Authority commented that while there are 86 registered administrators, it is not convinced that all of these entities can fully deliver on their obligations.
This is a time of increasing regulatory scrutiny, and proactive preparation will be essential to navigating the shifting landscape of pension supervision in Ireland.
About the author
Stephen is a Partner and Head of Pensions in Mason Hayes & Curran’s Employment Law and Benefits team.,specialising in Pensions Law.
He has extensive experience in advising trustees, sponsoring employers and pension providers on a range of issues, including pension scheme establishment; pension scheme funding and exercises to reduce scheme liabilities.
Stephen is experienced in drafting and updating pension scheme documentation and advising on pension scheme mergers and reorganisations. He regularly advises on the pension aspects of corporate acquisitions and disposals.
Stephen is a member of the Benefits Committee of the Irish Association of Pensions Funds and is a member of the Law Society’s Pension Committee.
