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The Minister for Social Protection signed legislation on 22nd April 2021 which officially transposes the Second European Pensions Directive (known as IORP II) into national law.


After over two years of anticipation, this publication brings a welcome certainty for trustees and employers, allowing them to plan effectively for the future of their schemes.   The legislation brings into force in Ireland the wide-ranging legal requirements and governance standards originally introduced in the IORP II Directive in 2017. Its arrival heralds the biggest change in the occupational pensions regulatory landscape in this country for a generation.


The Regulations closely follow the original European Directive, and Mercer have already been helping trustees and employers to work towards these requirements. In anticipation of the Directive, we have developed governance frameworks that trustees can tailor to their schemes and a pension risk management service to act as an outsourced risk management function for schemes.


Upcoming IORP II Compliance Deadlines – Annual Compliance Statement due by 31st January 2022!

Defined benefit and defined contribution pension schemes are now subject to an extended range of regulatory requirements under the new IORP II regime. The first key compliance milestone, whereby trustees must complete and sign their first Annual Compliance Statement before 31st January 2022, is fast approaching.


The Pensions Authority expects all schemes to be fully compliant with all IORP II requirements by 1st January 2023. It is vital, therefore, that employers and trustees consider their options and agree an appropriate plan to approach IORP II implementation over the course of 2022. 

The IORP II requirements principally cover:

  • Enhanced pension scheme governance and internal controls;
  • Strengthening schemes’ risk management systems, including a requirement for a formal risk management function;
  • Requirement for schemes’ to carry out an internal audit and have an internal audit function;
  • A much broader scope of member communications requirements, including provision of annual benefit statements to deferred members;
  • New fitness and probity standards for trustees and other persons involved in running schemes;
  • Extended powers for the Pensions Authority with respect to applying forward-looking, risk-based principles to the supervision of pension schemes and monitoring of compliance;
  • Updated rules relating to the operation of cross border schemes and transfers between schemes in Ireland and the EU.

How can we help you?


Mercer consultants, assisted by our designated IORP II and risk management teams, are subject matter experts and can help you prepare. We are already helping hundreds of schemes meet the new requirements. 


If you are concerned about your preparedness for the upcoming Annual Compliance Statement deadline, unsure of what IORP II means for your scheme, or would like to discuss any other aspect of the new IORP II regime and implementation options, please feel free to contact one of our dedicated team. 


Meet the team:



Please see important notices for regulatory information.

We’re here to help

We’d be happy to set up a free consultation or send you more information to get you started. Simply fill out the form below and we will be in touch. If you are an existing Mercer plan member and have a question about your pension or shares, please contact the JustAsk team via this link.


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