> ## Documentation Index
> Fetch the complete documentation index at: https://docs.pensionsportal.ie/llms.txt
> Use this file to discover all available pages before exploring further.
# Supervisory Review Readiness
> How the Pensions Authority reviews IORP II compliance and how to prepare for regulatory engagement under the SRP 2025–2029 framework
# Supervisory Review Readiness
The Pensions Authority has the statutory power to review any Irish pension scheme's compliance with IORP II at any time. Trustees who are unprepared for supervisory engagement — who cannot produce governance documentation on demand — face a compounded problem: the compliance gap they failed to address becomes immediately visible to the regulator.
**Supervisory review readiness** is not about preparing a document pack when a review is announced. It is about maintaining a continuous, auditable compliance record so that any regulatory engagement can be met promptly and confidently.
***
## The Supervisory Review Process (SRP) 2025–2029
The Pensions Authority's **Supervision 2025–2029 strategy** introduced the **Supervisory Review Process (SRP)** as the primary structured mechanism for assessing pension scheme governance. The SRP replaces ad-hoc desk reviews with a consistent, repeatable six-pillar framework.
The SRP is active from 2025. Every scheme assessed by the PA will be evaluated against all six SRP pillars. PensionsPortal.ie's SRP Evidence Pack module is designed to help trustees build and maintain evidence across all six pillars on a continuous basis.
The **Six SRP Pillars** and what the PA assesses under each:
| Pillar | PA Assessment Focus |
| ---------------------- | -------------------------------------------------------------------------------------------------------------------------------- |
| **1. Governance** | Quality of written policies; board meeting practice; KFH oversight; COI governance; decision-making records |
| **2. Operations** | Member data accuracy; contribution reconciliation; administration service standards; outsourcing oversight |
| **3. Risk Management** | ORA quality and currency; risk appetite statements; whether risks within/outside tolerance are identified; trigger-event reviews |
| **4. Communications** | Benefit statement accuracy and timeliness; member disclosure on material changes; ACS submission (where applicable) |
| **5. Investment** | IPS quality; investment monitoring; manager oversight; cost transparency |
| **6. Fees & Charges** | Total cost disclosure; VFM evidence; benchmarking against alternatives; member outcome metrics |
The PA does not consider pillars independently. Weaknesses in one area affect its overall assessment of governance quality. Trustees should aim to have evidence prepared under all six pillars at all times — not just for the pillars most relevant to recent events.
**PA's New Supervisory IT Platform (2026)**
The Pensions Authority is deploying a new supervisory IT platform in 2026, replacing its existing systems with a data-driven platform that includes automated submission validation and structured data ingestion. Schemes that submit high-quality, structured data will pass through the platform with minimal friction. Schemes with poor or inconsistent data are more likely to trigger automated queries and escalated supervisory engagement.
Trustees should treat 2025–2026 as the period to resolve outstanding data quality issues before the new platform goes live. See: [Data Quality →](/trustee-guide/data-quality)
***
## The Pensions Authority's Supervisory Approach
The Pensions Authority operates a **risk-based supervisory model**: supervisory resources are directed at schemes where governance failures present the greatest risk to member outcomes. However, risk-based supervision does not mean smaller schemes are immune — it means the Pensions Authority prioritises where it looks, not whether it looks.
The primary supervisory tool. The Pensions Authority issues a structured information request to the trustee board requiring submission of governance documentation within a fixed timeframe (typically 20–30 working days). Adequacy of documentation is assessed by Pensions Authority staff. This is the most common form of regulatory engagement.
Inspectors from the Pensions Authority visit the scheme's trustees or administrators to examine records and interview responsible persons. Inspectors have statutory powers under Section 18 of the Pensions Act 1990 to require access to premises and records.
Sector-wide reviews targeting a specific compliance area. Recent thematic reviews have covered governance policy adequacy, ORA quality, and KFH appointment completeness. **OMA compliance is expected to be a thematic priority in 2025–2026** given the April 2026 deadline.
Scheme events that trigger supervisory engagement: wind-ups, mergers, bulk transfers, member complaints, whistleblower reports, or failure to file the annual scheme return. Events that suggest governance weaknesses receive priority attention.
***
## What Triggers a Review?
The Pensions Authority may initiate a review for any of the following reasons:
The annual scheme return, ACS submissions (for DB schemes), and Pensions Authority information requests that are not responded to will trigger escalating supervisory engagement. Non-response is treated as evidence of governance failure.
A complaint from a scheme member — about benefit calculation errors, communication failures, or investment performance — may trigger a review of the scheme's broader governance arrangements. Member complaints are treated seriously even where they are ultimately unfounded.
Where the Pensions Authority identifies a sector-wide compliance issue (such as the OMA transition), it may conduct systematic outreach to all schemes in the affected category. OMA trustees should anticipate receiving correspondence from the Pensions Authority regarding the April 2026 deadline.
Wind-ups, mergers, and large-scale transfers attract regulatory scrutiny. The Pensions Authority will typically review governance documentation as part of its oversight of material scheme events.
The Pensions Authority collects data through annual scheme returns and other regulatory filings. Anomalies — funding shortfalls, large transfers, changes in KFH registrations — may trigger targeted follow-up.
***
## What the Pensions Authority Looks For
The items below map to the six SRP pillars. In a desk-based review or scheme visit, the Pensions Authority expects to see evidence across all six areas. For a trustee-facing walkthrough of the SRP Evidence Pack module, see [Supervisory Review Process →](/trustee-guide/supervisory-review-process).
In a desk-based review or scheme visit, the Pensions Authority expects to see:
### Governance Pillar
* A current, board-approved set of 11 governance policies — scheme-specific, not generic templates
* Review dates confirming policies have been reviewed within the last three years (or on material change)
* Board minutes demonstrating substantive governance discussion, not just formal approval of pre-agreed items
* COI register current for all trustees and KFHs with documented management outcomes
### Risk Management Pillar
* A completed, dated, and board-signed ORA
* Evidence that the ORA was discussed substantively at a trustee board meeting (not just circulated)
* An ORA that covers all Pensions Authority-required risk categories with scheme-specific analysis
* **Risk appetite and tolerance statements** — the ORA must state for each risk category whether current risk sits within or outside the trustees' defined tolerance
* Date of last ORA confirming it is within the three-year review cycle or that trigger events have been addressed
### Governance Pillar — KFH Records
* Appointment documentation for all four Key Function Holders (or three, if actuarial is not required)
* Fit and proper assessment for each KFH
* Pensions Authority notification for each KFH appointment
* Evidence of ongoing KFH reporting to the trustee board (board minutes, KFH reports)
### Operations Pillar — Outsourcing and Data
* Written outsourcing agreements for all material service providers, meeting Article 31 IORP II requirements
* An outsourcing register recording all providers, their functions, and PA notification status
* For outsourced KFH roles: evidence of Pensions Authority notification
* Evidence of adequate member communications (benefit statements, material change notifications)
* Evidence of data quality governance — accurate member records, reconciled contribution data
### Fees & Charges Pillar — VFM Evidence
* Documentation of a VFM assessment — trustees must have actively compared scheme costs against alternatives
* Benchmarking evidence (current scheme vs. master trust or DC consolidation vehicle)
* Member impact metrics (cost per member, cost ratio, fee drag)
### Investment Pillar
* A current Investment Policy Statement that reflects actual investment strategy
* Evidence of regular investment performance monitoring against the IPS
* Cost transparency: trustees must know the total cost of investment management
### Trustee Qualifications
* Records of trustee training undertaken (CPD records)
* Current fit and proper assessments for all trustees and KFHs
***
## The Evidence Pack: Supervisory Review Readiness
The concept of "supervisory review readiness" is simple: at any point, the trustee board should be able to produce a structured, complete, and time-stamped set of compliance documentation that answers every question the Pensions Authority is likely to ask. This is your evidence pack.
An evidence pack for a Pensions Authority desk review should contain:
1. **Scheme identification and trustee details** (scheme registration number, trustee names and roles)
2. **KFH appointment records** (appointment letters, fit and proper assessments, PA notification confirmations)
3. **Governance policy suite** (all required policies, version-controlled, with board approval dates)
4. **Board meeting minutes** (demonstrating governance in practice, at least 12 months)
5. **Own Risk Assessment** (most recent, dated, board-signed)
6. **ACS** (most recent, where applicable)
7. **Outsourcing register** (all providers, agreements, PA notification status)
8. **KFH reports to the trustee board** (annual reports from each KFH)
9. **Trustee training records** (evidence of ongoing CPD)
10. **Member communication samples** (benefit statements, material change notifications)
***
## The Role of PensionsPortal.ie
PensionsPortal.ie is designed specifically to support supervisory review readiness. Every compliance action taken within the platform is **time-stamped and stored in an immutable audit trail**. At any point, trustees can generate a complete evidence pack formatted for Pensions Authority review.
Every action in PensionsPortal.ie — policy approval, KFH appointment, ORA sign-off, board meeting minute — is recorded with a tamper-evident timestamp. The record is structured to demonstrate the sequence of governance activities.
One-click export of a regulator-ready evidence pack. The pack is structured to match the Pensions Authority's desk review information request format, minimising the time required to respond to a supervisory inquiry.
Real-time dashboard showing compliance status across all IORP II obligations. Outstanding items, approaching deadlines, and overdue reviews are highlighted. Trustees can see at a glance whether the scheme is supervisory-review-ready.
All notifications sent to the Pensions Authority are recorded, with dates and content. Trustees can confirm at any time that all required notifications are complete.
***
## Pensions Authority Powers
If the Pensions Authority identifies compliance failures during a review, it has a graduated range of enforcement powers:
| Power | Statutory Basis | When Used |
| --------------------------------- | ------------------------ | ----------------------------------------------------------------------------------------------- |
| Direction to Rectify | Section 63C Pensions Act | Compels trustees to address a specific compliance failure within a defined timeframe |
| Prohibition | Section 63D Pensions Act | Prohibits a trustee or service provider from acting in a specified capacity |
| Appointment of an Administrator | Section 63E Pensions Act | Replaces trustee governance where the Authority has lost confidence in the board |
| Prosecution | Section 3 Pensions Act | Criminal proceedings for certain statutory breaches; fines up to €50,000 on summary conviction |
| Wind-Up Direction | Section 48 Pensions Act | Compulsory wind-up where scheme continuation poses serious risk to members |
| Publication of Enforcement Action | Pensions Act, as amended | The Pensions Authority publishes enforcement actions, creating public reputational consequences |
The Pensions Authority's publication of enforcement actions means that regulatory failures are not private matters. A direction or prohibition against a trustee who is a company director or senior executive will be visible to employers, clients, and counterparties. Compliance is not just a legal obligation — it is a professional and reputational imperative.
***
## How to Prepare: A Trustee Checklist
Use this checklist to assess your scheme's supervisory review readiness today:
* [ ] Risk management policy: current, board-approved, reviewed within 3 years
* [ ] Investment policy: current, board-approved, reviewed within 3 years
* [ ] Remuneration policy: current, board-approved, reviewed within 3 years
* [ ] Contingency plan: current, board-approved, reviewed within 3 years
* [ ] Outsourcing policy (if applicable): current, board-approved
* [ ] Internal audit policy: current, board-approved
* [ ] Actuarial policy (if applicable): current, board-approved
* [ ] Four KFHs appointed (or three where actuarial is not required)
* [ ] Fit and proper assessments completed for each KFH
* [ ] Pensions Authority notified of each KFH appointment
* [ ] KFH annual reports received and minuted
* [ ] ORA completed within the last 3 years
* [ ] ORA covers all required risk categories
* [ ] ORA formally presented to and signed off by the trustee board
* [ ] ORA stored with time-stamp in the scheme's compliance record
* [ ] Written agreements in place for all material service providers
* [ ] Outsourcing register maintained and current
* [ ] Pensions Authority notified of any outsourced key functions
* [ ] Board meeting minutes for at least the last 12 months
* [ ] Minutes record attendance, decisions, and actions
* [ ] Trustee training records maintained
* [ ] Conflict of interest declarations current
If any item above is not checked, PensionsPortal.ie can help you close the gap before the Pensions Authority engages. [Contact us to assess your compliance position →](https://pensionsportal.ie/contact)