Compliance of new one-member arrangements

23 June 2022: Today, the Pensions Authority issues a further reminder to trustees of one-member arrangements (OMAs) established on or after 22 April 2021 of the imminent 1 July 2022 compliance deadline. The Authority also sets out its position on the continued establishment of non-compliant OMAs post 1 July 2022. 

Any OMA set up on or after 22 April 2021 must meet the full requirements of the Pensions Act, 1990, as amended (the Act), including the new requirements of the IORP II Directive, by 1 July 2022. These requirements impose significantly higher standards and requirements on Irish pension schemes, including OMAs established on or after 22 April 2021.

The Authority has concerns about the establishment of new OMAs since April 2021 and whether those pension schemes are complying with the Act. The new obligations introduced by the IORP II Directive are designed to maximise consumer protection and the Authority will not permit schemes to be non-compliant with the new requirements.

The Authority has specifically noted that many of the new OMAs have been established by insurance companies and has recently met with these companies to advise them of its concerns. The Authority advised insurance companies that the use of standardised trustee services and policies, key function holder appointments and audited accounts replicated across a large portfolio of OMAs is unlikely to meet the compliance threshold. The Authority further advised insurers that non-compliance of new OMAs will not be tolerated post 1 July 2022 and that enforcement action, up to and including prosecution may be taken against the pension scheme trustees responsible for running non-compliant OMAs.

After 1 July, the Authority will conduct a series of on-site and off-site inspections of OMAs set up after 22 April 2021, including by insurance companies. Individuals or companies who are trustees of such pension schemes are advised to check that they are compliant with their obligations and to contact their financial adviser or insurance company immediately if they have any questions.

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For further information, contact:

Technical Unit
The Pensions Authority
Tel: (01) 613 1900