Ireland’s Pensions Authority has launched a consultation into proposals to change the investment rules for personal retirement savings accounts (PRSAs).

There are two types of PRSA:

  • standard PRSA with maximum charges of 5% on contributions and 1% p.a. on the fund value. It may only be invested in pooled funds;
  • non-standard product with no limit on charges, allowing investment in funds other than pooled funds, such as property, loan notes and unregulated investments. 

Since the transposition of the IORP II Directive into Irish law, there has been an increased demand for PRSAs, most notably in the non-standard market, which has seen an almost fivefold increase in the number of new contracts.  

This is largely because the introduction of IORP II created barriers to the operation of executive pension plans and one-member small self-administered schemes, resulting in a substantial shift to PRSA business.

At the end of Q2 2025, PRSA assets stood at €20bn, 66% of which were in non-standard PRSAs.

“PRSA products allow similar investment freedoms afforded in a pre-IORP II world to continue,” said John Lynch, partner and actuary at LCP Ireland. “The combination of investment freedom and high contribution limits means that PRSAs are the natural home for many investors.”

However, the Authority said it is concerned about the disparity between the investment rules of PRSAs and occupational pension schemes, believing that these rules should be more closely aligned. Its view is that PRSA providers should be required to ensure assets are invested predominantly in regulated markets, and in a manner that ensures diversification.

The investment rules for occupational pension funds, set out in Section 59AB of the Pensions Act 1990, cover general principles for trustees, and rules for specific asset categories.  

The consultation is canvassing views on the Authority’s proposals, and on the timing and application of any new rules. It is also seeking views on proposals to require more detailed data returns from providers in relation to how PRSA contributors’ assets are invested.

Fergus Moyles, head of private wealth strategy at Mercer in Ireland, said: “In principle, it is positive to see efforts to reduce overconcentration in unregulated investments in the pensions industry to protect regular pension savers, and we support this.

“However, we can also understand that there will be many experienced investors or business owners who will be unhappy with these proposals, as they believe they have the experience and expertise to hold and direct such investments.”

He pointed out that a common feature of the self-directed pension industry has been the holding of residential property by self-employed or business owners in vehicles such as PRSAs, and said the changes would have a significant impact on that market.

Moyles suggested: “It would be interesting to consider whether there may be other alternative approaches available to protect the average pension saver, while still allowing flexibility for those to invest and manage properties in their pension who have the experience and expertise to do so.”

But Lynch warned: “Imposing an enhanced sense of fiduciary duty onto PRSA providers may prove a challenge, as ultimately the relationship is contractual, rather than the provider explicitly taking responsibility for investment choice. It is difficult to see how a PRSA provider could easily implement all of the requirements without a significant change to oversight.”

He said this would be particularly true for providers working on an open architecture basis and offering a PRSA product only, allowing savers the freedom to add any investments they choose.

Consultation submissions should be sent by e-mail by 5pm on 17 November 2025.

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