Ireland Pensions Update 

Industry Developments

Auto-enrolment (AE)

“MyFutureFund” officially launched on 1 January 2026 and the National Automatic Enrolment Retirement Savings Authority (NAERSA) has commenced collecting contributions.  All eligible employees (earning more than €20K p.a. and aged between 23 and 60) are automatically enrolled in MyFutureFund unless they are in “exempt employment”, i.e. employment where pension contributions are being paid through payroll to a qualifying occupational pension scheme, PRSA or Pan European Pension Scheme.  A statutory instrument was signed into law on 24 December 2025 to give effect to new “minimum standards,” i.e. for Defined Contribution Schemes/PRSAs, a minimum of 3.5% of gross earnings in total (or €2,800 p.a. if less) of which at least 1.5% of gross earnings must be paid by the employer (or €1,200 p.a. if less).  For Defined Benefit Schemes, the new standards can be met for an employee whose employment entitles the employee to accrue a long service benefit.

What does this mean for employers?

Employers will need to consider how the new minimum standards impact their occupational pension scheme/PRSA arrangements.

What does this mean for trustees?

Trustees will need to engage with the sponsoring employer to ensure steps are being taken if needed to ensure that the pension scheme is compliant with the new minimum standards.

For further information on auto-enrolment and minimum standards, click here

Mercer can support employers to understand the implications of AE on their business with a checklist of items for employers to consider. Please contact us for further information. 

Review of the Standard Fund Threshold (SFT) Regime

The SFT is the limit on the total capital value of tax-relieved pension benefits that an individual can draw down in their lifetime from all of that individual’s pension arrangements.   Changes to the SFT were announced in September 2024 following the publication of an independent review of the SFT and these changes were included in the Finance Act 2024.

For further information on the changes to the SFT please refer to the Standard Fund Threshold.

What should employers do now?

Employers should review whether their employees may be affected by this change and what steps will need to be considered.   For example, an option may be to permit employees previously impacted by SFT limits to rejoin the company pension plan.

Mercer can support employers to understand the implications of the changes to SFT. Please contact us for further information. 

The Pensions Authority issued a report in April 2025 sharing observations from its supervisory activities in 2024 which ranged from the Supervisory Review Process (SRP) with Master Trusts and larger DB/DC schemes to compliance audits of DB and DC schemes. The Pensions Authority are expected to issue a report by April 2026 with its observations on the 2025 SRP.

The Supervisory Review Process assesses governance, risks and trustees’ risk management capabilities. The Pensions Authority noted that trustees are expected to focus on enhancing governance practices, ensuring compliance with regulatory requirements and ultimately protecting the interests of scheme members.  Some of the key areas identified by the Pensions Authority related to conflicts of interest, decision making, maintaining comprehensive minutes and policies tailored to the specifics of the scheme, establishing oversight frameworks for robust governance and ensuring that member engagement policies are detailed and go beyond statutory obligations.

The Pensions Authority also highlighted value for money, investment, internal audit and fit and proper standards for trustees as areas that trustees should focus on.

What should trustees do now?

Trustees should engage with their scheme secretary/governance consultant to review the key areas and develop a plan to address any potential gaps and be prepared for future engagement with the Pensions Authority.

Mercer can assist trustees in relation to the new regulatory supervision. Please contact us for further information. Please visit the Pensions Authority website for further details on the Pensions Authority.

Deferred Annuities

Deferred annuities are now available in the Irish market bringing a much-needed DB solution for trustees, sponsors and most importantly members. Schemes will now be able to settle liabilities in respect of deferred members without the need to convert their benefits to a transfer value payable to a defined contribution arrangement.

What should trustees do now?

Trustees should explore if this is a suitable option.

Mercer can assist trustees in relation to this. Please contact us for further information. 

The Employment (Contractual Retirement Ages) Act 2025

The Employment (Contractual Retirement Ages) Act 2025 was signed into law in December 2025 although the Commencement Date is yet to be confirmed.  The legislation gives effect to the recommendation by the Pensions Commission to allow employees, who wish to do so, to work beyond their contractual retirement age and continue to work to the State Pensions Age (SPA) of age 66.

Employees, who want to keep working up to SPA, can notify their employer that they do not consent to retiring at their contractual retirement age where this is below the SPA.  

Employers will need to cede to such requests unless they can demonstrate an objectively justifiable legitimate aim and that the means of achieving that aim are appropriate and necessary.

It is expected that employers will see increased interest among their workforce in working for longer.

What should employers do now?

Longer working and flexible retirement can give rise to various legal and practical issues for employers including considering employment contractual provisions, staff policies and benefits matters as well as potential changes to the rules of the pension plan. As a first step, employers should consider the impact of employees working beyond their contractual retirement age on pay, pension and benefits.  

What should trustees do now?

Trustees may wish to consider assessing the potential impacts on their pension scheme (including the impact on integrated benefits on retirement) and death benefit schemes that will need to be addressed.

Mercer can support employers and trustees in preparing for this legislation once the commencement date has been announced.  We can also provide specific support in reviewing the provisions of the pension scheme and assist with any retirement policies that the employer and/or trustees may wish to consider implementing. Please contact us for further information.

Digital Operational Resilience Act (DORA)

DORA sets uniform requirements for the security of network and information systems and creates a regulatory framework on digital operational resilience whereby financial entities will need to make sure they can withstand, respond to, and recover from IT disruptions and threats.  The Pensions Authority has stated that “Trustees will bear ultimate responsibility for ensuring their scheme’s compliance with the requirements, irrespective of any outsourcing arrangements in place” and “Almost every Irish pension scheme outsources its administration, and trustees must ensure that their administrator’s systems are reliable, efficient and robust, and provided them with all the information needed to meet their management and governance obligations.”  The Pensions Authority has a dedicated page on their website which includes a FAQ and guidance to trustees.

What should trustees do now?

Trustees should ensure they are complying with ongoing DORA legislation on a regular basis and that they are prepared for regular and any ad hoc reporting to the Pensions Authority. 

Mercer can support trustees to ensure they maintain their DORA compliance status. Please contact us for further information.

The Social Welfare (Bereaved Partner’s Pension and Miscellaneous Provisions) Act 2025 and recent case heard by the High Court

The Act relates to State benefits and allows qualified cohabitants to receive the widow’s, widower’s and surviving civil partner’s pension for the first time reversing a previous restriction, which limited payments to married or civil partnership couples.  The Act was changed as a result of a supreme court case which was taken by a qualified cohabitant who had originally been refused the widow’s pension.

In early 2026, the High Court granted a declaration in a different case that the failure of the Civil Service Spouses & Children’s Pension Scheme (Public sector scheme) to provide a spouse’s/civil partner’s pension to a surviving partner who had a financial dependence was unconstitutional. 

What should employers and trustees do now?

The legislation relates to State benefits and does not impose any obligations on employers or trustees. The recent High Court case relates to a public sector scheme and may be subject to appeal. Employers and trustees of private occupational schemes may wish to review the eligibility provisions of the pension scheme for death in service benefits. 

In 2026, trustees will be conscious that the Own Risk Assessment is due for most schemes in early 2027 and should start planning for this.

Mercer can support trustees with their risk management services. For further information visit here.

Trustees will also be conscious of their fit and proper requirements under the Code of Practice for Trustees and their obligation to complete trustee training every two years since their appointment.  With the introduction of DORA, supervisory review process with the Pensions Authority, governance obligations under IORPs II and general trustee duties and obligations, trustees may wish to review their knowledge levels and decide on topics for training in 2026.

The Code of Practice for Trustees requires trustees to appoint a scheme secretary.  Appointing a scheme secretary to prepare a business plan, run meetings, manage stakeholders and trustee actions as well as ensuring governance obligations are being met can greatly assist trustees in keeping on top of their governance requirements and allows trustees to focus on the strategic items and most importantly, best member outcomes.

Mercer can support trustees with their scheme secretarial and governance consultancy services. See here for further information on Mercer's secretarial service scheme.

Mercer can also support trustees with a range of trustee training topics. Please contact us for further information.