Executive pensions and business owners: April 2026 IORP II deadline is now imminent

With the regulatory deadline arriving on 22 April 2026, business owners and professionals with one member pension arrangements must prepare to transition without delay. For this group, whose financial lives rarely align with the simplicity of PAYE structures, the need to act promptly is particularly important

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. However, 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 Pensions Authority has since made it clear that one 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. That derogation ends in April 2026, and impacted schemes must take action now. 

The question facing scheme trustees and members 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 (PRSA), Personal Retirement Bonds, Approved Retirement Funds, 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 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 offers individuals the chance to realign their pension strategy with their broader financial objectives. The Standard Fund Threshold has now risen to €2.2 million and will increase to €2.8 million by 2029, with further inflationary increases to apply thereafter. This creates renewed opportunity for those with the means to contribute, provided their chosen pension structure supports it.

At the same time, new limits introduced in January 2025 on employer contributions to PRSAs have reduced their appeal 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 2026

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.

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. However, time to act is running out. 

If you are affected by the IORP II 22 April Deadline, please contact your adviser. If you are new to Davy, why not book a consultation.