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Regulatory Reporting and Pensions Authority Interaction

This page explains the reporting obligations that Irish occupational pension scheme trustees have towards the Pensions Authority, the submission channels available, and how PensionsPortal.ie supports trustees in meeting these requirements.
There is currently no general-purpose API or integration layer for third-party pension software to submit reports directly to the Pensions Authority. Trustee annual reports, audited accounts, and compliance documents are prepared and retained by trustees and their advisers, with only specific data returns submitted electronically through Authority or Central Bank channels.

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What Gets Filed with the Pensions Authority

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Trustee Annual Reports (TARs)

Trustees must ensure an annual report is prepared for every occupational scheme year, including:
  • Financial statements and membership information
  • Investment performance and strategy summary
  • Actuarial statements (for DB schemes)
  • Compliance and governance disclosures
The TAR is primarily a disclosure document for members, unions, and other stakeholders. The Occupational Pension Schemes (Disclosure of Information) Regulations 1991 (S.I. 332/1991) require it to be prepared and made available — it is not routinely uploaded to the Authority as a standard filing package.
The Pensions Authority can require trustees to furnish annual accounts, annual reports, SIPPs, ORAs, and other documents at any time for prudential supervision purposes. Trustees must be able to produce these on request.

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Electronic Data Returns

The following are submitted electronically through Authority or Central Bank channels:
ReturnFrequencyDeadlineChannel
Scheme Information ReturnAnnual9 months after scheme year endPensions Authority portal
Actuarial Data ReturnAnnual (where applicable)Per statutory timelinePensions Authority portal
ECB/EIOPA Statistical DataAs requiredPer CBI scheduleCentral Bank of Ireland reporting systems
DORA RegistersTBCTBC — Authority will give noticeTBC — expected to be Authority-specified
ECB/EIOPA data returns are submitted through Central Bank of Ireland reporting systems, not through the Pensions Authority directly. This applies to certain larger schemes that fall within the ECB/EIOPA statistical reporting scope.

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Audited Accounts

  • Trustees must cause audited annual accounts to be prepared where required
  • Since the Pensions (Amendment) Act 2022, this includes OMAs and small schemes
  • For schemes with over 100 active and deferred members, an auditor must review the annual report
  • The audit requirement is separate from filing data returns — audited accounts form part of the TAR disclosure package

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Supervisory Approach

The Pensions Authority’s supervisory model is risk-based and uses:
  • Investigations and inspections
  • Thematic reviews
  • Desk-based audits
  • Information requests
In this context, the Authority may request reports, accounts, policies, and governance documents. This is done through direct communication with trustees — not via standardised external APIs.

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Future Reporting Channels

The Authority has indicated that new data collection arrangements are being developed for:
  • EIOPA data requirements — structured pension scheme data for European supervision
  • DORA registers — ICT third-party provider registers required under the Digital Operational Resilience Act
The Authority has acknowledged the “technical and practical issues involved” and has committed to providing notice and guidance when these arrangements are finalised. Any new channels are expected to be tightly specified submission formats rather than general-purpose APIs.

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PensionsPortal.ie’s Role

PensionsPortal.ie is designed to generate, manage, and store the compliance documents that trustees need — not to submit them to the Authority on trustees’ behalf.

Document Generation

Generate board-ready compliance documents: Health Checks, ORAs, ACS, policy documents, KFH assessments, and governance reports — all exportable as PDF.

Evidence Pack

Maintain a complete audit trail and evidence pack that trustees can furnish to the Authority on request, including version history, sign-off records, and timestamps.

Deadline Tracking

Track regulatory deadlines including scheme information return due dates, policy review cycles, and KFH re-assessment dates.

Data Export

Export scheme data in structured formats suitable for populating Authority data returns, reducing manual re-entry.
Workflow: PensionsPortal.ie generates compliance documents → trustees review and approve → trustees or their administrators submit data returns through the Authority’s own channels. PensionsPortal.ie provides the content; the Authority provides the submission mechanism.

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References