The Irish Pensions Authority has signalled a tougher supervisory regime for occupational pension schemes, warning trustees they will need stronger governance, sharper oversight of service providers and more robust management of conflicts of interest to meet the standards expected under a forthcoming authorisation regime.
In its 2025 supervisory activities report, the regulator said trustees should treat findings rated high or medium/high as issues that would need to be addressed to maintain authorised status, directly linking current supervision with standards expected under the proposed authorisation regime due later in 2026.
The authority said several schemes reviewed last year had serious shortcomings that trustees had failed to identify, including poor governance, weak risk management, inadequate oversight of administration and poor documentation of conflicts of interest.
The regulator said trustee boards must be properly resourced, have the right mix of skills and be able to demonstrate that decisions are recorded, followed up and implemented, rather than simply discussed in principle.
It also warned that all potential conflicts of interest must be identified, documented and managed within decision-making processes, with master trusts specifically told to scrutinise founder-related conflicts.
The authority is also increasing scrutiny of operational resilience. It said trustees must not simply rely on administrators and service providers, but instead set their own requirements, monitor service levels and establish clear escalation and exit strategies where performance is poor.
It added that trustees need to ensure cyber risk is embedded within their risk management framework and that Digital Operational Resilience Act (DORA)-related registers, policies and procedures are in place.
It said: “Consistently poor performance cannot continue unchecked and must be addressed by trustees”.
Master trusts are expected to face the heaviest scrutiny, with regular interaction through supervisory reviews and meetings. The authority flagged retail master trusts as a particular focus for 2026, especially regarding investment governance, due diligence around transitioning funds and unregulated market investments, and oversight of member communications and behaviour.
The regulator also criticised the persistence of one-member arrangements within master trust structures, saying these do not align with its expectation of efficient, well-run schemes capable of delivering economies of scale.
For personal retirement savings accounts (PRSAs), the authority said all products will now be subject to enhanced supervision because of their growing asset base, and providers should expect increased engagement in 2026.
One provider was already placed under enhanced supervision last year following concerns identified in annual reporting, with monthly reporting required until the issues are resolved.
