EU Pensions Policy: EIOPA Consults on New Sustainability Reporting Requirements for IORPs

The European Insurance and Occupational Pensions Authority has launched a consultation on proposed sustainability reporting requirements for institutions for occupational retirement provision, which will have significant implications for Irish pension schemes operating under the IORP II framework.

The consultation, which runs until the end of June 2026, sets out EIOPA's preliminary proposals for standardised disclosure of climate-related risks, ESG investment exposures, and stewardship activity by occupational pension funds across the EU. The proposals draw heavily on the Task Force on Climate-related Financial Disclosures framework and the EU's own Sustainable Finance Disclosure Regulation, which already applies to certain financial products offered by Irish pension schemes.

For Irish trustees, the most significant elements of the proposals relate to Scope 3 emissions reporting and portfolio alignment metrics. EIOPA proposes that schemes above a certain asset threshold be required to disclose the weighted average carbon intensity of their investment portfolio, along with an assessment of portfolio alignment with a 1.5 degree warming scenario. The proposals also include requirements for schemes to disclose their stewardship and engagement policies, including how they vote on climate-related shareholder resolutions.

PensionsEurope, of which the IAPF is a member, is coordinating a joint industry response and has raised concerns about the proportionality of the proposals for smaller schemes, the availability of underlying data from asset managers, and the timeline for implementation. The IAPF is inviting member schemes to share their views on the proposals by the end of May, so that Irish perspectives can be incorporated into the PensionsEurope response.

A briefing webinar for IAPF members will take place on 22 May. Registration is available through the events section of the member portal.