The IORP II Directive has not yet been transposed into Irish law, despite the passing of the deadline, Sunday, 13th January 2019.  The Department of Employment Affairs and Social Protection have indicated in response to an inquiry from the IAPF, that the Department, supported by the Pensions Authority, is working towards the transposition during Q1 of 2019. ( ).

Many commentators expected the Pensions Authority to exempt smaller schemes from the provisions of the Directive, as each Member State is entitled to do.  However, the indications are that the Pension Authority are not going to do so, resolute in their belief that the full protections of the Directive, should apply equally to all pension schemes, regardless of size.  This is likely to trigger significant change across the industry.

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