DORA deferral for Irish pension schemes
Lawyers at A&L Goodbody have highlighted a recent update from the Pensions Authority on the obligations facing Irish pension schemes under EU legislation on financial firms’ digital operations.
The Digital Operational Resilience Act (DORA) aims to increase the resilience of the European financial market and reduce the risk of cyber-attacks.
The Pensions Authority confirmed late last month that Irish pension schemes would not have to submit a register of information (ROI) until 2028.
ROIs list all contractual arrangements on the use of technology services provided by third-party providers. They are intended to be used to designate critical third-part service providers under DORA.
‘Preparation time’
The pensions body issued the update after the European Supervisory Authorities (ESAs) simplified their processes for collecting ROIs.
In a note on the ALG website, the firm’s lawyers note that, while the deferral eases immediate pressure on reporting, it does not change the underlying obligation for trustees to maintain a complete, accurate, and ‘live’ ROI.
“The update reinforces that trustees should use the additional time to strengthen data quality, oversight, and evidence ahead of the 2028 submission,” they add.
“Deferral should be treated as preparation time, not a relaxation of supervisory expectations,” the ALG lawyers conclude.