Two major pension updates collide;
– One of the European regulations relating to ‘Exec Pensions’ and ‘Small Self Administered’ schemes (SSAS) that affect self-employed drivers
– One of the income related to employees and losing control of their collective pension schemes after the ‘normal retirement age’ (NRA)
Both can change where your pension is located, how it is invested and when you can access it.
And all this can happen without you saying it, if you do nothing.
Key points I will share today;
- What the European IORPS2 deadline really means for Executive and SSAS pensions
- How automatic moves to Master Trusts work
- The major change in income that limits pension transfers from occupational pension schemes
- Why early retirement plans are the most visible
- Which practical steps make sense now?
Why 2026 is a line in the sand for executive pensions:
If you have an Executive Pension or SSAS, April 30 is an important date this year.
IORP II is an EU rulebook that Ireland passed into law in 2021 through the Regulations for occupational pension schemes.
It tightens up what trustees have to do in terms of governance, risk, supervision and communication with members, and Ireland is apparently the member state that has implemented it (we’re brave, so we are!).
For most people with an Executive Pension or SSAS the big point is this:
• These are usually single-member arrangements
• The Pensions Authority has said that the IORP II derogation for single-member schemes will expire in April 2026
• Your scheme must be compliant by then, otherwise you risk enforcement measures
If your pension has one participant and one trustee who is also you, IORP II actually says: great, but you still need good governance. The paperwork now has paperwork.
After April 2026, most of these standalone ‘single member’ schemes will no longer be allowed to operate in their current form.
Trustees must either fully comply with the IORPS2 rules (which are onerous) or terminate the scheme.
For most small Executive and SSAS schemes, full compliance is not achievable.
The result?
Automatic transfer to a Master Trust, often without any active decision from you!
IORPS2 explained without headaches
IORPS2 is an EU directive designed to improve governance and member protection. Sounds reasonable.
In practice, it adds onerous compliance rules and processes to trustees
- Risk management frameworks
- Ongoing monitoring obligations
Big plans can accommodate this. Small Executive and SSAS schemes usually cannot do this.
So what happens?
- Members move to a Master Trust
What happens if my pension is transferred to a Master Trust?
Master trusts deserve a few blogs in their own right, but for high level information for now.
A master trust is a defined contribution occupational pension scheme, where many employers are covered by one master trust deed, with professional governance built in. It centralizes the compliance obligations set out in IORPS 2, and spreads the burden across many different schemes, spreading the costs and burdens.
Positives
• IORP II governance is handled for you, including trustee governance structure and policies
• Reduced trustee costs for you and your company (if applicable)
• It’s easier to stay on the right side of deadlines when the rules change
• Often smoother administration for contributions, reporting and communication
And one of the big benefits (for some) of using a Master Trust is the ability to use the ‘Revenue Max Funding’ calculations to determine the amount your company can contribute to the scheme each year, as opposed to the ‘100% of your annual salary’ maximum currently allowed by your employer in PRSAs.
Disadvantages
• Less flexibility on unusual assets, such as direct real estate or tailor-made investments (which could be restricted via PRSAs in the near future anyway – more on that in the future)
• You go to a standard investment menu, not a customized portfolio or set of options
• Oversight of service providers and trustees can feel less personal and less aligned with your other assets and overall planning
• Transition work to Master Trust still exists, and it can become difficult if administration is messy
A good decision question for you:
• Do you want control, or do you want less administration and input?
• If you want control, are you willing to pay for good governance
What alternative do I have to control trusts?
The reality is that your Trustee has already made the changes for you, but if that is not the case and you are considering whether or not to move to Master Trust, here is one of the main alternatives for most Exec/SSAS holders.
Switching to a personal pension savings account?
The PRSA is the Ying to the Master Trust Yang in terms of personalization and investment choice (currently!).
Currently, one can invest in a wide range of assets, funds and stocks/shares through a PRSA. The employer can contribute up to 100% of your total compensation in that calendar year, and you have great flexibility in withdrawing and managing the assets. In addition, you can contribute to your age-related maximum percentages yourself.
For example, if you are a 52-year-old owner/director and received total compensation of €110,000 in 2025, the company was allowed to transfer €110,000 in cash to your PRSA and receive a full corporate tax exemption on that amount, and you pay no benefit in kind on that amount. In addition, you were entitled to a personal contribution of a total of 30% of € 110,000 (€ 33,000), and received a full tax reduction of 40% (€ 13.2k).
And here’s the kicker: for most (but not all), these allowances are likely enough to build up the pension pot they need before retirement.
But recognizing that there are others who will be subject to the ‘revenue Max Funding’ calculation depending on their salary, service, age and existing pension assets,really oneProvide a higher level of funding, where the business can support this and the director wants or needs to do so to build an appropriate pension for his circumstances.
2) Major change in income in your company pension audit
This change is isolated, but arguably more important for those approaching retirement.
If you are a participant in an ’employer’s pension scheme’ / ‘occupational group scheme’ / ‘work scheme’, call it whatever you want, from August 2025, you need to know the following.
Before this change (later in 2026), on leaving employment, before or after your normal retirement age (NRA) in the scheme, you could transfer your occupational scheme to a PRSA or other structure to gain one or more of the following benefits:
- Take control and place assets into your own personal scheme
- Gain access to funds, assets and structures not available within the group plan
- Access to structures that allow flexible and tax-efficient withdrawal, such as a PRSA, or multiple PRSAs (read here from 2022) – Move your company pension to PRSAs
- potentially improve death benefits and give your partner access to 100% of the pension value as tax-free money if you die before withdrawal
- Improved personalization and service tailored to your financial planning through consultancy
From later this year you will only be able to transfer the value of your ‘group scheme’ to a personal pension scheme (PRSA or PRB etc.). for your normal retirement age (NRA).
Once you reach the NRA, transfers are largely blocked.
This applies to all company schemes.
And it’s driven by the rules of the Revenue Commissioners.
Why does this matter?
Because many executive pension holders:
- Want flexibility when taking pension benefits
- Expect to restructure closer to retirement
If you drift past the NRA without action, the options quickly narrow. This will catch a lot of people off guard.
Normal retirement age explained simply
The normal retirement age is not the date you plan to retire. It is the age stated in your scheme rules.
Often this is 65, sometimes 60 and occasionally later.
Two problems:
- Many people don’t know their NRA
- Master Trust’s default settings are built around it
If your plan is to slow down at age 55, the NRA is still making decisions unless they change. That mismatch can cost you dearly.
Who should act now?
All this is most important if you:
- A company director with an Executive Pension or SSAS
- A senior executive in his fifties
- A high earner who is considering taking a step back
- Plan your pension before you turn 65, but don’t think about taking your pension until later
- Not sure where your pension will end up in 2026?
If you see yourself here, time is important.
The true cost of doing nothing
We see this regularly.
- Portfolios have been placed in overly cautious funds with ten to fifteen years to go
- Others take too little or too much risk without knowing it
- Costs that quietly erode results
- Missed opportunities in the field of tax planning
None of this is dramatic or fast, but it is slow and can be expensive.
What a good pension assessment entails
A review is not about selling or buying a product. It’s about clarity about your options and actions.
You should come away knowing:
- Where your pension is likely to move
- Whether the investment mix fits your timeline
- What costs you pay or will pay
- How NRA affects your options and planning
- How this pension fits in with everything else you own
Practical steps before April 2026
You don’t have to revise everything tomorrow. But you have to participate.
Some simple steps to address both major changes coming;
- Confirm which type of pension you have
- Check your normal retirement age
- Ask what will happen to your scheme after April 2026, if this has not already been discussed
- Understand the August 2025 transfer restriction and whether it will impact your plans
- Get an independent review
That’s it. Simple steps that can make a big positive difference in your future choices and outcomes.
Major pension updates in 2026 will quietly reform many Executive and SSAS pensions in Ireland. Automatic moves, stricter transfer rules and fixed retirement ages mean that your pension will end up on a path you never chose. If you plan to retire early, want to change volatility and risk levels, or just want clarity, these changes matter.
Decisions are made by you or for you. And when it comes to pensions, timing is everything.
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