EUROPE – The Irish pensions regulator says two UK companies have applied to register pension funds in Ireland under the new European Union pensions directive.

Pensions Board chief executive Anne Maher said Ireland has not been able to register the funds yet until the directive is implemented in Ireland – which she said would be by April 2005. She did not name the companies.

Earlier this month it emerged that computer firm IBM was likely to become one of the first multinational companies to use the common contractual fund, Ireland’s new tax transparent pooling vehicle, to pool its pension funds’ global equity assets.

Maher said the directive, Institutions for Occupational Retirement Provision, could prove a “catalyst for very major change” in the European pensions landscape. European member states have until September 2005 to implement the measure.

Speaking at a conference organised by The Economist, Maher said the directive could lead to “regulatory arbitrage” – where companies choose the country with the regulation that suits them.

But she said a single EU-wide pension model would be too inflexible. She said the directive represents the first step towards pan-European pensions. “Certain synchronisations will be needed,” she said, in areas such as statistics and terminology.

And an EU-wide pension system would require strong cross-border cooperation of supervisors which was “easier said than done”.

Maher also said the “jury is still out” on Ireland’s new personal pension products known, Personal Retirement Savings Accounts. “It may be that we’ll need some form of action to incentivise or coerce them into making some contributions,” she warned.