The update covers recent announcements from the Pensions
Authority and Revenue Commissioners, pensions measures in the
Finance Act 2022 and recent pensions case law.
1. IORP II compliance
1.1 IORP II compliance deadline
On 1 January 2023, the Pensions Authority's (the
“Authority”) IORP II compliance deadline for
employer-sponsored schemes expired. Employers and trustees of
schemes which are not in compliance with IORP II requirements after
this date run the risk of investigation and prosecution by the
Authority.
As noted in our Autumn Update, the Authority has confirmed that
where a formal commitment has been made prior to 1 January 2023 to
wind-up a pension scheme and transfer the assets of the scheme to a
master trust or to PRSAs, the trustees will not be required to meet
the new IORP II requirements provided that the transfer will be
completed, and the scheme wound up, by the end of 2023.
