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January 12, 2026
Sometimes, yes. But only if you act early and put an alternative in place.
If you have an Executive Pension/SSAS or are a member of an Occupational Pension Scheme approaching retirement, you might want to know about these big changes coming your way!
Two major pension updates are colliding;
- One from European regulation relating to 'Exec Pensions' and 'Small Self Administered' schemes (SSAS) which impacts self employed directors
- One from Revenue relating to employees and losing control over their group pension schemes after 'Normal Retirement Age' (NRA)
Both can change where your pension sits, how it is invested, and when you can access it.
And all of it can happen without your say so, if you do nothing.
Key points I'll share today;
If you hold an Executive Pension or SSAS, April 30th this year is a big date.
IORP II is an EU rulebook that Ireland brought into law in 2021 through the Occupational Pension Schemes Regulations.
It tightens what trustees must do on governance, risk, oversight, and member communications, and Ireland is apparently the land member state to have implemented it (we're bold so we are!)
For most people with an Executive Pension or SSAS, the big point is this:
• These are usually one member arrangements
• The Pensions Authority has said the IORP II derogation for one member schemes ends in April 2026
• Your scheme must comply by then, or you risk enforcement action
If your pension has one member and one trustee who is also you, IORP II basically says: lovely, but you still need proper governance. The paperwork now has paperwork.
After April 2026 most of these stand-alone, 'single member' schemes will no longer be allowed to operate in their current form.
Trustees must either fully comply with IORPS2 rules (which are heavy), or wind up the scheme.
For most small Executive and SSAS arrangements, full compliance is not viable.
The result?
Automatic transfers into a Master Trust, often with no active decision from you!
IORPS2 Explained Without the Headache
IORPS2 is an EU directive designed to raise governance and member protection. Sounds reasonable.
In practice, it adds heavy compliance rules and processes on Trustees
Large schemes can absorb this. Small Executive and SSAS schemes usually cannot.
So what happens?
Master trusts deserve a couple of blogs by themselves, but for high-level info for now.
A master trust is a defined contribution occupational pension scheme, where many employers sit under one master trust deed, with professional governance built in. It centralises the compliance obligations set out by IORPS 2, and shares that load across many different schemes, spreading the costs and burden.
• IORP II governance is handled for you, including trustee board structure and policies
• Less trustee burden for you and your business (if applicable)
• Easier to stay on the right side of deadlines as rules change
• Often smoother admin for contributions, reporting, and communications
And one of the big advantages (for some) of using a Master Trust is the ability to use the 'Revenue Max Funding' calculations to determine the amount that your company can contribute to the scheme each year, as opposed to the '100% of your annual salary' maximum currently allowed into PRSAs from your employer.
• Less flexibility on unusual assets like direct property or bespoke holdings (which may become restricted via PRSA's in the near future anyway - more on that in future)
• You move into a standard investment menu, not a custom portfolio or suite of options
• Provider and trustee oversight can feel less personal, and less aligned to your other assets and overall planning
• Transition work to Master Trust still exists, and it can get fiddly if records are messy
A good decision question for you:
• Do you want control, or do you want less admin and input?
• If you want control, are you willing to pay for governance properly
The reality is that your Trustee will already have made the changes for you, but if not, and you are considering whether to move to Master Trust or not, here is one of the main alternatives for most Exec/SSAS holders.
Move to a Personal Retirement Savings Account?
The PRSA is the Ying to the Master Trust Yang in terms of personalisation and investment choice (currently!).
Currently one can invest in a wide suite of assets, funds and stocks/shares via a PRSA. The employing company can contriubute up to 100% of your total remuneration in that calendar year, and you have great flexibility on draw-down and control over the assets. Plus you can contribute personally up to your age-related maximum percentages.
For example, if you are 52 year old owner/director and took a total remuneration of €110k during 2025, the company was allowed to transfer €110k cash to your PRSA, and get full Corporation Tax relief on that, and you pay no Benefit in Kind on that amount. In addition, you were entitled to make personal contributions totally 30% of €110k (€33k), and get full 40% personal tax relief (€13.2k) on that.
And here's the kicker - for most (but not all), these allowances are probably sufficient to build the pension pot they need to before retirement.
But acknowliding that there are others where the 'revenue Max Funding' calculation, depending on their salary, service, age and existing pension assets, might allow a larger level of funding, where the company can support it and the director wants or needs to do so in order to build an appropriate pension for their circumstances.
No. It can work well. It just should not be accidental.
This change is separate, but it is arguably more important for those approaching retirement.
From August 2025, if you are a member of an 'employer pension scheme' / 'occupational group scheme' / 'work scheme', call it what you will, you need to know the following.
Prior to this change (happening later in 2026), upon exit from employment, either before or after your Normal Retirement Age (NRA) on the scheme, you could transfer your Occupational scheme to a PRSA or other structure in order to achieve one or more of the following benefits:
As f later this year you will only be able to transfer the value of your 'group scheme' and into a personal pension scheme (PRSA or PRB etc) before your Normal Retirement Age(NRA).
After you reach NRA, transfers are largely blocked.
This applies across occupational schemes.
And it is driven by Revenue Commissioners rules.
Why does this matter?
Because many Executive Pension holders:
If you drift past NRA without action, options narrow fast. This will catch many people off guard.
Normal Retirement Age Explained Simply
Normal Retirement Age is not when you plan to retire. It is the age written into your scheme rules.
This is often 65, sometimes 60 and occasionally later.
Two problems:
If your plan is to slow down at 55, NRA still drives decisions unless changed. That mismatch can cost you.
All of this matters most if you are:
If you see yourself here, time matters.
The Real Cost of Doing Nothing
We see this regularly.
None of this is dramatic or quick but it is slow, and can be expensive.
What a Proper Pension Review Covers
A review is not about selling or buying a product. It is about clarity on your options and actions.
You should come away knowing:
Practical Steps Before April 2026
You do not need to overhaul everything tomorrow. But you do need to engage.
Some simple steps to address both major changes approaching;
That is it. Simple steps that could make a large positive difference in your future choices and outcomes.
Major pension updates in 2026 will quietly reshape many Executive and SSAS pensions in Ireland. Automatic moves, tighter transfer rules, and fixed retirement ages mean your pension may end up on a path you never chose. If you plan to retire early, alter volatility and risk levels, or simply want clarity, these changes matter.
Decisions will be made either by you or for you. And in pensions, timing is everything.
The content of this site including blogs and podcasts is for information purposes only. Everybody’s financial situation is different and the content we share on our site and through podcasts may not be applicable to you.
The articles, blogs and podcasts are not investment advice. They do not take account of your individual circumstances, including your knowledge and experience and attitude to risk. Informed Decisions can’t be held responsible for the consequences if you pursue a course of action based on the information we share
Possibly. But the structure and timing matter more than ever.
Informed Decisions are one of Ireland’s only remaining independent financial advice firms. We specialise in retirement & investment planning for successful individuals, so that our clients only have to retire once.
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