Oireachtas Joint and Select Committees

Thursday, 7 November 2019

Joint Oireachtas Committee on Social Protection

Transposition of IORP II Directive: Discussion

Mr. David Harney:

Yes. I think a cost-benefit analysis will ultimately show that this should not be applied to smaller schemes. If an analysis is carried out and shows that the provisions should be implemented, that is fine. However bypassing the cost-benefit analysis seems to be a mistake. That is not that controversial. People can debate the findings of a cost-benefit analysis. Our view is that it will find that one-man arrangements are not collective schemes and should be fully exempt. An analysis may go further than the UK analysis. IORP II is to be implemented across Europe. An analysis may conclude that in light of the protections and information requirements already in place, Ireland is pretty well positioned on schemes with between 1 and 100 members and there is no need to implement a lot of these provisions anyway.

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