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IORP II Governance Framework

The IORP II Directive requires every Irish occupational pension scheme to implement an effective system of governance — a structured set of policies, processes, controls, and people that ensures the scheme is managed in the interests of members and beneficiaries. This requirement is set out in Article 21 of IORP II and transposed in Part VIB of the Pensions Act 1990 (as inserted by the Pensions (Amendment) Act 2022, implementing S.I. 128/2021). The system of governance is not a tick-box exercise. The Pensions Authority expects trustees to demonstrate that governance arrangements are proportionate to the nature, scale, and complexity of the scheme — and that they are operative in practice, not merely documented.

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System of Governance: Core Requirements (Article 21 IORP II)

The proportionality principle means a smaller scheme may apply simpler governance structures than a large multi-employer scheme. However, proportionality reduces how requirements are implemented, not whether they apply. All schemes subject to IORP II must have a system of governance.
Article 21 requires every IORP to have in place, at minimum:
  1. Written governance policies covering all material risk areas
  2. A risk management function (with an appointed Key Function Holder)
  3. An internal audit function (with an appointed Key Function Holder)
  4. A compliance function (with an appointed Key Function Holder)
  5. An actuarial function, where the scheme provides biometric risk coverage, investment performance guarantees, or defines benefit levels (with an appointed Key Function Holder)
  6. An internal control system encompassing the above functions
  7. Human and technical resources adequate to support governance
Each Key Function Holder must meet fit and proper requirements under Article 23 IORP II. See KFH obligations →
Written Scheme Management Procedures (CoP §4): In addition to written governance policies, trustees must have written procedures for scheme management that identify: (a) all members of the trustee board, KFHs, service providers, and other parties involved in managing and administering the scheme; (b) a clear allocation of each party’s respective tasks; and (c) a list of scheme activities with statutory timeframes and completion dates. Documented evidence that these procedures are being followed must be retained.
Secretary and Chairperson (CoP §6): Trustees must appoint a secretary to the board (even where scheme rules do not require it). The secretary is responsible for circulating the agenda and relevant paperwork in advance of meetings, and for recording minutes. Trustees must also appoint a chairperson to lead trustee meetings and ensure all agenda items are addressed.
Minimum Number of Trustees (s.64AC Pensions Act 1990 / CoP §113): Section 64AC of the Act requires the appointment of at least two persons as trustees who effectively run the scheme. For sole corporate trustees, this requirement is satisfied where at least two directors effectively run the scheme.

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Written Policies: What Is Required

The governance framework must be underpinned by a suite of scheme-specific, board-approved written policies (CoP §10–12). Generic templates that have not been adapted to the scheme’s circumstances do not satisfy this requirement.

Investment Policy

Required under Article 30 IORP II. Must cover investment objectives, asset allocation, permitted asset classes, risk limits, use of derivatives, and ESG/sustainability considerations. Must align with the scheme’s ORA risk appetite.

Risk Management Policy

Required under Article 25 IORP II. Documents the risk management framework, risk appetite, risk tolerance limits, risk identification methodology, and the process for escalation and reporting. The policy must also include a risk-scoring system with provision of risk ratings and a defined procedure for the Own-Risk Assessment (ORA) (CoP §51). The risk management process must be well-integrated into trustee decision-making.

Remuneration Policy

Required under Article 22 IORP II (CoP §26). Must cover: the policy’s objectives; roles and responsibilities of all parties involved in determining remuneration; procedures for determining remuneration for trustees, KFHs, outsourced service providers, and any other personnel employed by the trustees; safeguards to ensure remuneration does not generate excessive risk-taking or conflicts of interest; provisions ensuring remuneration is not solely based on financial performance metrics; a provision that early termination payments must reflect long-term performance and not reward failure; and the frequency, form, and content of reporting arrangements. The policy must be reviewed and updated at least every three years (CoP §27).

Contingency Plan

Required for operational continuity. Must identify key dependencies, business continuity arrangements, and the process for managing a significant operational disruption.

Outsourcing Policy

Required where the scheme outsources any activity or function. Must define the criteria for selecting service providers, oversight mechanisms, and escalation procedures (Article 31 IORP II / CoP §19–25). All outsourcing arrangements must be governed by written, legally enforceable contracts that include: commencement/end dates, obligations and deadlines, data protection, sub-outsourcing conditions, business continuity, dispute resolution, pricing, and handover provisions. Trustees remain responsible for compliance regardless of outsourcing.

Internal Audit Policy

Documents the scope, frequency, methodology, and independence requirements for the internal audit function (CoP §67). Scope must cover: scheme administration (in-house); trustee oversight of outsourced functions; trustee investment decisions; scheme governance; risk management; contributions handling; legislatively mandated compliance; IT systems management; fit and proper requirements; and disclosure requirements. Must include: the process for addressing and tracking audit findings (with timelines for remediation); reporting requirements and trustee response timeframes; and how often the policy will be reviewed.

Actuarial Policy

Required where the actuarial function is active. Covers the scope of the actuarial function, the basis for actuarial assumptions, and the process for producing and reviewing the ACS.

Data Strategy

Required under Article 21(5)(f) IORP II (CoP §13–14). Documents how the scheme manages data quality, data security, member data accuracy, and IT system governance. Must include the nature, scope, and timeliness of data needed, the methods for obtaining it, and how accuracy is verified. Trustees are also responsible for ensuring data is handled in accordance with GDPR. Compliance with this policy must be reviewed at least once annually — this is more frequent than the standard 3-year policy review cycle and applies in addition to it — and findings must be documented.

Administration Policy

Required under CoP §36. Trustees must create and maintain a written administration policy covering: Purpose (goals of the policy, procedures for appointing and monitoring administrators); Scope (administrator obligations, registered administrator responsibilities, other administration functions); Roles and responsibilities (administrator, trustees, employer, and service providers); Information requirements (type, source, and frequency of information to be received); Reporting (information the administrator must provide to trustees, KFHs, and the Authority); Monitoring and review (frequency of performance monitoring); and Review of policy (how often, by whom, and in what circumstances the policy is reviewed). Documented evidence of compliance and periodic review must be maintained.

Member Engagement Policy

Required under CoP §29. Trustees must prepare a written policy regarding how they will engage with members and beneficiaries. The policy must address: the objectives of engagement; the occasions on which engagement will occur; the frequency of engagement; and the forms of communication that will be used. The policy must be reviewed at least every three years and updated to ensure it continues to serve the needs of scheme members. Trustees must keep a log of all queries and complaints received from members. Members may request access to any policy document within four weeks of the request (CoP §31).

Conflicts of Interest Policy

Required under CoP §17. Trustees must have a written policy on conflicts of interest for themselves and for the KFHs they engage. The policy must cover: description of the types of conflict that may arise (including conflicts concerning trustees, KFHs, service providers, and employers); a register of trustees’ and KFHs’ interests which could give rise to such conflicts; the process for managing identified conflicts; and whether conflicted trustees will be allowed to vote on conflicted matters. Compliance with this policy must be reviewed at least once annually (CoP §18) and findings documented — this annual compliance review is in addition to the standard 3-year policy review. The policy itself must be reviewed at least every three years.

Statement of Investment Governance

Required under CoP §70–73 (separate from and in addition to the SIPP). Trustees must have a written statement outlining the governance process whereby investment objectives and strategy will be decided and implemented. For DB schemes, it must address: investment objectives and risk tolerance; the process for agreeing investment strategy; ESG factors; investment management structure; and information for assessing investment performance. For DC schemes, it must also address: investment choices to be offered; strategy and risk tolerance for each choice and the default investment; and review frequency. This statement must be reviewed at least every three years and whenever amendment of the investment governance process is planned. It must be available to members on request.

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Policy Review Cycle

All written policies must be reviewed at least every three years, and immediately following any significant change in the scheme’s operations, risk profile, or regulatory environment. A policy that has not been reviewed within three years is a compliance deficiency that the Pensions Authority will identify in a desk review.Exception — Annual compliance reviews required (in addition to the 3-year policy review):
  • The Data Strategy policy compliance must be reviewed at least annually (CoP §14).
  • The Conflicts of Interest policy compliance must be reviewed at least annually (CoP §18).
Each policy review must be:
  • Conducted formally by the trustee board (or by a delegated committee with board oversight)
  • Recorded in trustee meeting minutes
  • Evidenced by a revised, dated, board-approved policy document
  • Stored in the scheme’s compliance evidence trail
  • Retained in a format available for inspection by the Pensions Authority, including all minutes, documentation of decisions, advice (other than privileged), expert reports, and information upon which decisions were based (CoP §12)

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Governance Structure

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Trustee Board Composition

Section 64AC of the Pensions Act 1990 requires at least two persons as trustees who effectively run the scheme. For sole corporate trustees, this is satisfied where at least two directors effectively run the scheme. Beyond this statutory minimum, the governance system must be adequate for the complexity of the scheme. The Pensions Authority’s Code of Practice provides practical guidance on appropriate board composition. Key considerations:
  • Collective competence: The board as a whole must have the knowledge, skills, and experience to govern the scheme effectively
  • Independence: For larger schemes, the Pensions Authority expects evidence of independent thinking and challenge in trustee decision-making
  • Member representation: Where required by scheme rules or legislation, member-nominated trustees must be included
Trustee Qualification Requirements (CoP §107–108): At minimum, at least one trustee on the board (or one director of a sole corporate trustee) must either: (a) have completed a trustee qualification course listed on the Pensions Authority’s website; or (b) have been a trustee or director of a sole corporate trustee of a similar type of scheme for at least two of the previous three years. The Pensions Authority’s preference is that both the qualification and experience requirements are satisfied by different individuals on the board, to avoid over-reliance on one trustee or director.
Annual Skills Assessment (CoP §119): As part of the competence policy, the trustee board must assess the skills, knowledge, and experience of the board annually to identify gaps that need to be filled through recruitment or further training. There must be documented evidence of the conclusions reached and the follow-up actions taken.

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Meeting Frequency and Minutes

Trustees must establish a written procedure for the planning and running of meetings (CoP §5). Minutes of meetings must provide written evidence of the extent to which this procedure has been followed. There is no statutory minimum meeting frequency for all schemes, but the Pensions Authority expects a documented meeting schedule proportionate to the scheme’s governance needs:
  • Trustee boards of DC master trusts must meet at least once per quarter (CoP §7 — mandatory, not a guideline)
  • Other active schemes should hold sufficient meetings to maintain effective oversight and control
  • Smaller or closed schemes may meet less frequently, but must evidence that governance obligations are being discharged between meetings
  • All decisions with compliance implications must be formally minuted
  • No one trustee should have unfettered powers of decision in the management of a scheme (CoP §7)
Agenda Requirements (CoP §8): The agenda for regular meetings must be circulated in advance and must include consideration of:
  1. Conflicts of interest
  2. Risk
  3. Issues of non-compliance
  4. Administrative matters
  5. Member queries and complaints
Minute-taking requirements (CoP §9): Minutes must be taken at every trustee meeting and subsequently reviewed and approved by the trustees. The minutes must record:
  1. The date, time, and place of the meeting
  2. The names of the trustees who did attend the meeting
  3. The names of the trustees who did not attend the meeting
  4. Details regarding any other persons (such as service providers) who attended
  5. A summary of the discussions held and all decisions made
  6. Action points, deadlines, and identification of the persons assigned responsibility for progressing each item
Minutes are a primary evidence source in Pensions Authority supervisory reviews. Vague or incomplete minutes undermine the credibility of the governance framework.

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Own-Risk Assessment (ORA)

The ORA is a distinct and mandatory governance process under CoP §52–59. It is separate from the risk management policy.
Trustees must have a documented Own-Risk Assessment (ORA) process to identify and assess material risks that threaten achievement of the scheme’s objectives. The ORA process must address:
  • Frequency: Scheduled ORAs must be performed at least once every three years, with an additional ORA required without delay following any significant change in the risk profile of the scheme
  • Content: The ORA must contain a comprehensive assessment of the overall position of the scheme including challenges, risks to members’ benefits (by member class), operational risks (benefit records, member communications, contribution handling, IT systems), potential impact of trustee decisions on risk, adequacy of death benefit insurance, and (where the same person performs key functions for both the scheme and the employer) conflicts of interest arising from that duality
  • DB schemes: Must additionally address the current funding position, factors that led to that position, a quantitative evaluation of solvency and financial risk, the trustees’ view of the strength of the employer covenant, and risks identified from periodic funding review
  • Integration: ORA results must be integrated into trustee decision-making processes and must provide guidance on actions to mitigate identified risks
  • True assessment: The ORA must provide a true assessment of risk, not merely a rationalisation of the scheme’s current position

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Fit and Proper Requirements (Article 23 IORP II / Section 64AV Pensions Act)

All trustees and Key Function Holders must satisfy fit and proper requirements on appointment and on an ongoing basis.
Important distinction (CoP §104–105): ‘Fit’ (appropriate qualifications, knowledge, and experience) is a collective obligation for the trustee board — the board as a whole must be fit. ‘Proper’ (good repute and integrity) is an individual obligation — every trustee and every KFH must individually be of good repute and integrity.

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Knowledge and Experience (‘Fit’)

  • Understanding of IORP II obligations and Irish pensions legislation
  • Relevant professional or sector experience
  • Understanding of the specific scheme (its members, investments, funding structure)
  • For the trustee board, collective competence is assessed (CoP §104)

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Fitness (Capability — KFH-specific requirements)

For Key Function Holders, the trustees must ascertain that each KFH (CoP §121–122):
  • Holds a qualification considered relevant by the trustees at a minimum of Level 7 on the Irish National Framework of Qualifications (NFQ), or an equivalent professional qualification
  • Has a minimum of two years’ experience gained in relevant employment
  • Has appropriate knowledge to perform the key function competently
  • Has a clear and comprehensive understanding of the governance, regulatory, and legal environments relating to the key function
  • Can demonstrate the ability to manage concurrent responsibilities
  • Is aware of their obligation to identify and report personal conflicts of interest
  • For each KFH appointment, trustees must retain documentation showing how they ascertained the KFH met the fit requirement (CoP §123)

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Propriety (Good Character — ‘Proper’)

‘Proper’ means being of good repute and integrity (CoP §109). An individual’s qualification as ‘proper’ could be adversely affected by conditions including (but not limited to):
  • Being a sole trader, director, or partner in a legal entity prohibited, suspended, or restricted from carrying on a regulated trade or profession in any jurisdiction
  • Being the subject of any upheld complaint to any regulatory body relating to activities regulated by the Pensions Authority or an equivalent authority
  • Having been dismissed or asked to resign (other than in the normal course of business) from any profession, vocation, office, employment, or position of trust or fiduciary appointment
  • Having been a director of a company struck off the Register of Companies on an involuntary basis
  • Having been disqualified or restricted from acting as a director or in any managerial capacity
  • Having been removed as a trustee under section 63 of the Pensions Act
  • Having been convicted of an offence involving money laundering, terrorist financing, fraud, misrepresentation, dishonesty, or breach of trust, or being subject to current proceedings for same
  • Having been disciplined or suspended by a regulatory or professional body
  • Having defaulted on payments due because of a compromise or scheme of arrangement made with creditors
  • Being subject to an unsatisfied judgment debt in any jurisdiction
  • Being or having been the subject of a bankruptcy petition
  • Having been adjudicated a bankrupt (undischarged)
  • Having been a director of an entity subject to insolvency

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Ongoing Training and Compliance

Trustees and KFHs must maintain and develop their competence through ongoing training. The Pensions Authority’s Code of Practice specifies minimum training expectations. Trustees must be able to evidence the training undertaken. Trustees and directors of sole corporate trustees must also:
  • Undertake trustee training
  • Have a policy in place for acquiring and maintaining a mix of skills, knowledge, and experience adequate for good governance
  • Formally review and document their compliance with fit and proper requirements on an annual basis (CoP §115)
  • Assess board skills, knowledge, and experience annually to identify gaps, with documented conclusions and follow-up actions (CoP §119)
KFH ongoing compliance (CoP §129): Trustees must ensure KFHs continue to meet fit and proper requirements on an ongoing basis. At least once every three years, and whenever a KFH is being considered for reappointment, trustees must review and document whether the KFH has maintained compliance. KFH selection procedure (CoP §127): Trustees must have detailed written procedures for selecting and appointing KFHs, including: how fit and proper requirements will be ascertained; a clear description of duties and responsibilities; a process matching the selected person to role requirements; details of required professional qualifications; a requirement to hold an up-to-date signed CV with proof of qualifications and expertise; and a process for verification of professional references. KFH removal procedure (CoP §130): Trustees must have a written procedure for the removal of KFHs, including a non-exhaustive list of circumstances that would trigger consideration of whether a KFH has breached fit and proper requirements.
Pensions Authority Notification (CoP §106): Where a trustee or KFH does not meet — or ceases to meet — fit and proper requirements, trustees must notify the Pensions Authority. This is a mandatory ongoing obligation.
PensionsPortal.ie’s Fit & Proper Tracker records the individual assessment of each trustee and KFH, stores supporting evidence, and alerts trustees when re-assessment or training refreshes are due.

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Internal Control System

The internal control system encompasses all three lines of defence:
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First Line: Operational Management

The trustees and scheme administrators who own and manage day-to-day risks. Responsible for implementing controls as specified in governance policies.
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Second Line: Risk and Compliance Functions

The Risk Management KFH and Compliance KFH provide independent oversight of first-line activities. They set risk frameworks, monitor compliance, and report to the trustee board.
3

Third Line: Internal Audit

The Internal Audit KFH provides independent assurance on the effectiveness of the first and second lines. Specific responsibilities include monitoring regulatory compliance, challenging current practices, and identifying training needs (CoP §66). Internal audit findings must be reported to the trustee board, and remediation must be tracked to completion with defined timelines.
Accounting Procedures (CoP §45): The internal control system must also include accounting procedures that define how the scheme will record, classify, and summarise financial transactions, and how Trustee Annual Reports (TARs) or Alternative Annual Reports (AARs) will be prepared. These procedures must cover: financial transaction recording; daily, monthly, and/or annual reconciliation requirements; TAR/AAR preparation timelines; roles and responsibilities of trustees, administrators, and independent accountants; and procedures for appointing an external auditor.
Review of Internal Controls (CoP §63): Internal controls must be reviewed at least once every three years, or more often when substantial changes have taken place (including deterioration in a DB scheme’s funding, a change in investment manager, or realisation that an existing control is inadequate). Assessments should include internal audits and spot checks.
Scheme Reporting Arrangements (CoP §68): Trustees must ensure that clear communication processes and procedures are established for obtaining, providing, and reporting information necessary for the operation of the scheme. These processes must be kept under ongoing review and adapted as needed to meet scheme objectives and assist with managing identified risks.

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Administration (Chapter 2 — Code of Practice)

This section summarises the administration requirements set out in Chapter 2 of the Code of Practice (CoP §33–42).

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Administrator Performance Oversight

Regardless of whether administration is performed in-house or outsourced, trustees must follow written oversight and reporting procedures. Key requirements:
  • Quarterly monitoring: The administrator’s performance must be monitored on a quarterly basis (CoP §40)
  • Annual reviews: Formal reviews of administrator performance must be conducted at least once annually, evaluated against the contract and SLA (CoP §40)
  • Critical review: At least once every three years (or earlier if concerns arise), trustees must conduct an in-depth critical review of the administrator’s performance against contractual obligations. The critical review forms the basis for a decision on whether to retain or replace the administrator. A tender process must be initiated where the critical review gives rise to issues of concern, including value for money concerns (CoP §41)
  • Decision documentation: The reasons for retaining or changing the administrator must be clearly documented in the critical review (CoP §42)

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Employer’s Role in Administration

Trustees must have a full understanding of the employer’s role in scheme administration, including the processes used by the employer to provide information to the administrator. Trustees must take reasonable steps to have a written agreement with the employer regarding the provision of data to administrators, and must review these processes at least once every three years (CoP §38).

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Investment Governance (Chapter 4 — Code of Practice)

This section summarises the investment governance requirements set out in Chapter 4 of the Code of Practice (CoP §69–91).

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Investment Strategy

Trustees must specify in writing clear quantitative and qualitative targets for the scheme’s rate of investment return and risk tolerance. The investment strategy must be written in plain language so that trustees can monitor and implement it without relying on experts to interpret it. Stated objectives must be specific, quantifiable, and verifiable (CoP §74–76). The investment strategy must include: objective for rates of return; maximum acceptable level of investment risk; procedures for maintaining legislatively mandated investment obligations; ESG factors to be considered; and a requirement that the strategy be reviewed at least every three years.

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Investment Manager Oversight

  • Investment performance must be monitored on a quarterly basis and reviewed at least annually (CoP §87)
  • A critical review of investment manager performance must be conducted at least once every three years (extendable to five years in defined circumstances) (CoP §87)
  • The selection and review process for investment managers must be based on a set of written criteria drawn up in advance, including fee impact on investment outcomes (CoP §79)
  • When an incumbent investment manager is retained following a critical review, trustees must clearly document why they chose this course of action (CoP §88)
  • Investment contracts must not contain provisions that limit the trustees’ ability to obtain information from the investment manager or that impair trustees’ ability to review and replace the investment manager (CoP §85)

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Safekeeping and Depositary Arrangements

Trustees must ensure proper safekeeping and administration of scheme assets (CoP §91). Where required, a depositary must be appointed in accordance with the applicable legislative requirements. Trustees must satisfy themselves that asset custody arrangements are appropriate, secure, and regularly reviewed.

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Defined Benefit Financial Management (Chapter 5 — Code of Practice)

This section applies to trustees of defined benefit (DB) schemes only. It summarises the requirements set out in Chapter 5 of the Code of Practice (CoP §92–102).
Trustees of DB schemes must have a thorough understanding of the scheme’s solvency position, the financial risks facing the scheme, the likelihood that additional employer support will be required, and the scheme’s sustainability (CoP §93). Trustees must review solvency using multiple actuarial bases including: the basis underlying the funding standard; the best estimate of future conditions; likelihood that current investment conditions will persist; and bases unfavourable to the scheme (CoP §96). Trustees must commission quantitative estimates of financial risk that include the Pensions Authority’s defined benefit financial risk measure (CoP §101). Trustees must also form a comprehensive view of the scheme’s ability to absorb financial risks through regular discussions with the sponsoring employer, assessing the employer’s ability and willingness to provide supplemental contributions if needed (CoP §102).

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DC Master Trust — Additional Requirements (Chapter 7 — Code of Practice)

This section applies to DC master trusts only. It summarises the additional requirements set out in Chapter 7 of the Code of Practice (CoP §131–155). These requirements are in addition to all governance requirements above and reflect the heightened regulatory expectations for master trust structures.
DC master trusts are subject to enhanced governance, structural, and operational requirements beyond those applicable to standard occupational pension schemes.

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Structure and Composition

  • The trustee must be a Designated Activity Company (DAC) whose sole stated objective is to act as trustee of the master trust
  • The board must have a minimum of two directors
  • At least one director must be independent of the sponsoring employer(s) and service providers
  • The chairperson of the board must be independent

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Capitalisation

Master trusts must maintain a minimum wind-up reserve at all times:
  • €70 per member in the scheme
  • Subject to a minimum floor of €100,000
Trustees must demonstrate that sufficient liquid assets are available to meet this reserve at all times.

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Continuity Plan

Master trusts must have a detailed continuity plan that includes:
  • Three-year forward financial projections demonstrating the viability of the master trust
  • A defined wind-up mechanism, specifying how member assets would be transferred or protected in the event of the master trust’s discontinuation
  • Trigger points that would activate the continuity plan

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Charges Transparency

Master trusts must have a written charges transparency policy setting out the charges applied to members’ accounts, how charges are calculated, when they are applied, and how they will be communicated to members.
  • Marketing consent: Before a master trust can be marketed to a prospective employer, the trustee must ensure appropriate consent procedures are in place
  • New member enrolment: New members must provide informed consent to enrolment in accordance with the requirements of CoP §131–155

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Mandatory Reporting to the Pensions Authority

Master trust trustees must report certain events to the Pensions Authority without delay. Mandatory reporting events include (but are not limited to):
  • Scheme closure or proposed wind-up
  • Persistent material non-compliance
  • Liquidity stress or inability to maintain the required wind-up reserve
  • A significant change in the control or ownership structure of the trustee DAC
  • Any event that materially affects the continuity or security of member assets

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Enhanced Conflicts of Interest

Master trusts are subject to enhanced conflicts of interest requirements, reflecting the commercial nature of the master trust model and the potential for conflicts between the trustee’s commercial interests and members’ interests. The conflicts of interest policy must specifically address conflicts arising from the master trust’s commercial relationships with employers and service providers.

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PensionsPortal.ie Governance Module

PensionsPortal.ie provides an integrated governance module that operationalises the system of governance for Irish pension trustees.

Policy Registry with Version Control

Every governance policy is stored centrally with full version history. Review due dates are tracked automatically. Superseded versions are archived but accessible for audit purposes. Board approval is recorded against each version.

Meeting Management

Board meeting scheduling, agenda builder, and minute-taking templates. Actions from meetings are tracked to completion. Meeting records form part of the exportable evidence pack.

Board Pack Generation

Automated pre-meeting board packs that compile governance status, outstanding actions, policy review schedule, KFH reports, and ORA status into a single document ready for trustee review.

Fit & Proper Tracking

Individual trustee and KFH profiles with fit and proper assessment records, training history, conflict of interest declarations, and Pensions Authority notification status.

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Pensions Authority Reference

The Pensions Authority has published a Code of Practice for Trustees (November 2021) that provides detailed guidance on meeting the IORP II governance requirements. Trustees should read this alongside the legislation.
This document has been reviewed line-by-line against the Pensions Authority Code of Practice for Trustees of Occupational Pension Schemes and Trust Retirement Annuity Contracts (November 2021) by 137th Consulting on 1 March 2026. It is for information and guidance purposes only and should be reviewed by a qualified pensions lawyer or compliance professional before reliance for regulatory compliance purposes.