What IORP II means for executive pensions and business owners in Ireland

New pension rules are forcing a strategy reset. For business owners and professionals, whose financial lives often sit outside the simplicity of PAYE models, the stakes are particularly acute.

Pensions have long played a central role in the financial strategies of this group, but rarely through conventional means. Single or one-member arrangements like Executive Pension Portfolios (EPPs) and Small Self-Administered Schemes (SSASs) offered what standard products could not - control over investment decisions, access to advice, and the ability to align retirement savings with broader business, tax, and estate planning.
But the framework that enabled that autonomy is coming to an end.

Understanding IORP II and Its impact on pension holders

The IORP II Directive, originally transposed into Irish law in 2021, was designed to enhance governance, transparency, and risk management across European occupational pensions. The Irish Pensions Authority has since made it clear that single member arrangements, even if well-run, do not meet the directive’s standards. A five-year derogation was put in place, allowing existing schemes to continue temporarily. But that window closes in April 2026, and as of this month, we are one year out.

The question facing pension holders is not whether change is required. It is what form that change should take.

Alternative pension structures for business owners and executives

A number of alternative structures are available: Personal Retirement Savings Accounts (PRSAs), Personal Retirement Bonds, Approved Retirement Funds (ARFs), and, in certain cases, overseas arrangements. Each has its own particular pros and cons. But for those seeking continuity in terms of funding, flexible investments and advice, one structure is takes precedence; the master trust. More specifically, self-directed master trusts are likely to be the structure of choice for those seeking a pension structure that is most closely aligned with the benefits provided by one-member arrangements.

The master trust model

This model is gaining traction, and for good reason. It preserves much of the autonomy that made single -member schemes appealing, while introducing the scale, compliance, and oversight demanded by the new regulatory framework. For professionals and owner-directors used to tailoring their financial strategies closely to their personal goals, it offers a familiar degree of flexibility, within a more robust institutional wrapper.

Impact of increased Standard Fund Threshold

This call to action also presents a chance for individuals to bring their pension strategy back into alignment with wider financial objectives. The increased Standard Fund Threshold (SFT), announced in Budget 2025, allows high earners to build retirement benefits of up to €2.8 million by 2029, significantly more than the previous €2 million cap. This creates renewed opportunity for those with the means to contribute, provided their chosen structure supports it.

At the same time, new limits introduced in January 2025 on employer contributions to PRSAs have altered their attractiveness as a funding vehicle for company directors and owner-managers. What was previously a flexible catch-all pension structure may now fall short for those seeking to maximise retirement funding through their businesses.

Reevaluating your retirement plan in 2025

Against this backdrop, structure matters, but so too does intent. Retirement planning begins with the question: what are you trying to achieve? What age do you want to step away from your business or profession? What kind of lifestyle do you want to maintain? How much income will be required, and how secure, or flexible, should that income be?

Answering these questions can bring clarity, not only to the choice of most suitable pension vehicle, but also to the strategic decisions that need to be made to deliver an effective long-term plan for your finances.  For many, pensions have been an area of passive planning, set up once, reviewed infrequently, and often siloed from broader financial strategy. That approach is no longer fit for purpose. Regulation has forced a decision, but the more strategic view is to treat this moment as a reset. A chance to take control—not just of compliance, but of long-term personal outcomes.

Time is now a factor. Significant financial transitions of this nature shouldn’t be carried out last minute. Choosing the appropriate structure, aligning it with your goals, and ensuring a smooth migration of assets and strategy all require careful consideration. Those who act early will have the space to make deliberate, well-supported decisions. Those who delay may find themselves reacting under pressure, with fewer opportunities to tailor their approach, and greater risk of being funnelled into default options that prioritise compliance over fit.

The real opportunity lies in treating this not as a compliance burden, but as a chance to build a better plan for the future.  The structures that will deliver that, such as self-directed master trusts, can offer you more than just compliance. They can support the goals, freedoms, and control that business owners have always valued. But the time to act is now.

Taking proactive steps to secure your financial future

By taking proactive steps now, business owners and executives can implement a pension structure that meets their specific needs and supports their long-term financial objectives.

If you would like to learn more about our self-directed master trust, please contact your adviser. If you are new to Davy, why not book a consultation.