Impact of IORP II on Trustees

Compliance with IORP II

IORP II was transposed into Irish law in April this year. The changes introduced have a significant impact on the role of trustees of occupational pension schemes, and will require a sizeable amount of work by them to achieve compliance, particularly in relation to governance and being considered fit and proper for the role.

As a result, Standard Life will no longer set up a new Synergy Executive Pension which appoints the Principal Employer as trustee.

Synergy Executive Pensions will be required to appoint a professional trustee company.


Choosing a professional trustee

We have partnered with Lane Clark and Peacock Trustee Services (LCPTS) to provide independent professional trustee services as part of our Synergy Executive Pension Plan. Find out more on our Synergy Executive Pension page.

Alternatively, you can appoint a professional trustee of your choosing.

Our Synergy Executive Pension application form has been updated to reflect the option of selecting a professional trustee service only.


Requirements for trustees under IORP II


  • Trustees must put in place effective governance and internal controls

Fit and Proper

  • Trustees must have adequate qualifications, knowledge and experience
  • Trustees must provide evidence of how they satisfy this requirement

Key function holders

  • Key function holders must be appointed to maintain effective risk management, internal audit and actuarial functions
  • The same person cannot carry out each role
  • They must provide evidence that they have adequate qualifications, knowledge and experience

Written policies

  • Trustees must have written policies for each of the key functions and these must be reviewed every 3 years
  • A risk identification and assessment framework must be established and carried out every 3 years

Annual Compliance Return

  • An annual compliance return must be submitted to the pensions authority each year

Communication with members

  • Pension benefit statements and Annual Reports must be provided each year to members in line with the directive’s requirements

View this document from the Pensions Authority for more information.


Supporting you at every step

If you’ve any questions about IORP II, please contact our technical solutions team at

If you wish to remove an existing trustee and appoint a professional trustee to an existing executive pension please contact They can discuss the process with you and provide the necessary documentation.

Synergy Executive Pension Application


Updated Application Form


Synergy Executive Pension Application Form

If you need any additional information please contact your Business Manager.