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Unpacking the IORP II Directive in Pension Fund Management

The Institutions for Occupational Retirement Provision (IORP) Directive, known as IORP II, marks a significant regulatory development in the European pension sector. Effective from January 13, 2019, this revised directive harmonizes the supervision of European pension funds, focusing on enhancing transparency, governance, and cross-border activities.

Key Changes Introduced by IORP II

IORP II revises the original directive with a focus on:

  • Strengthened governance structures.
  • Enhanced risk management requirements.
  • Implementation of the Own Risk Assessment (ERB).
  • Improved transparency and communication with pension beneficiaries.
  • Facilitation of cross-border collective value transfers.

Implications for the Dutch Pension Sector

In the Netherlands, where 90% of employees accrue pensions through their employers, IORP II impacts risk management and governance, especially in key function design and environmental, social, and governance (ESG) considerations.

Setting Up Key Functions under IORP II

IORP II mandates the separation of key functions within pension funds into administration, advice, and control, ensuring that these roles are not combined in one individual. European pension funds must have independent key officers for the actuarial function, the risk management function, and the internal audit function, adhering to strict requirements set by supervisory authorities like DNB.

Conducting Own Risk Assessment (ERB)

The ERB, a requirement under IORP II, must be conducted at least every three years. It involves identifying material risks, embedding risk management in decision-making, and assessing the quality of risk management, resulting in a report to the regulator.

Supervision and Compliance

The Dutch Central Bank (DNB) is responsible for prudential supervision, while the Authority for the Financial Markets (AFM) oversees behavioral supervision, focusing on communication with members and pensioners.


1. What is the IORP II Directive?

The IORP II Directive is a European pensions directive aimed at harmonizing the supervision of pension funds across the EU, focusing on governance, risk management, and transparency.

2. How does IORP II affect pension funds in the EU?

IORP II affects EU pension funds by enforcing stricter governance structures, risk management practices, transparency in operations, and communication with pension beneficiaries.

3. What are the key functions under IORP II?

Key functions under IORP II include the actuarial function, risk management function, and internal audit function, each requiring independent officers.

4. What is the Own Risk Assessment (ERB) in IORP II?

The ERB is a periodic assessment that pension funds must conduct to identify and manage material risks, ensuring robust decision-making processes.

5. Who supervises compliance with IORP II in the Netherlands? In the Netherlands, the DNB oversees prudential supervision, and the AFM is responsible for behavioral supervision, particularly in terms of member communication.