Is Investing in Property Through Your Pension Coming to an End?

If you currently hold property in your pension, or have been considering it as part of your retirement strategy, recent developments reported in the Irish Times should be on your radar. Proposed changes to how Irish pensions can invest in property and other non-standard assets could significantly reshape the landscape for self-directed pension investors.

If you are a business owner or senior executive with a self-directed pension (particularly one holding property or using borrowing to invest), these proposed changes could directly affect your retirement strategy.

Here is what we know so far and what it could mean for you.

What Is the Pension Authority Proposing?

The Pensions Authority has launched a consultation on bringing the investment rules for non-standard Personal Retirement Savings Accounts (PRSAs), into line with the stricter IORP II regulations that already apply to one-member occupational schemes, including the structures that replaced SSAS and executive pensions.

This follows concerns about high-profile losses in unregulated loan notes and questions about whether some self-directed pension investors are taking on risks that may not be appropriate for retirement savings.

The key direction of travel is tighter limits on unregulated and direct property investments, combined with a clamp-down on borrowing inside pensions.

The Main Changes Under Consideration

While no final rules have been published, the consultation points towards a tightening across the board rather than a single, simple ban.

  • Aligning PRSA and one-member scheme rules: The Pensions Authority has indicated that the current broad investment freedom in non-standard PRSAs should be more closely aligned with IORP II-style safeguards. In practice, this means extending similar limits on unregulated and property assets to PRSAs and other non-standard arrangements, not just company schemes.
  • Tighter limits on direct property: For one-member schemes under IORP II, new investments in unregulated markets are already capped at 49 per cent of the plan value, with look-through to property held inside funds. The Authority is considering further restrictions on unregulated investments, which would catch a significant portion of direct property and bespoke arrangements.
  • Possible ban on certain assets: The consultation explicitly raises the possibility of banning some unregulated investments for pension schemes altogether. Industry bodies have warned this could effectively end many forms of property investing through pensions if applied without exemptions.
  • Borrowing restrictions: Under IORP II-style rules for one-member schemes, no new borrowing is allowed. Only borrowing that was in place before April 2021 can continue under its existing terms. Extending this logic to other pensions would effectively end the current ability of many self-directed pensions to gear into property, even if historic loans can run off.

The April 2026 Deadline You Cannot Ignore

There is a critical compliance deadline that is also worth noting, in tandem with these proposed investment restrictions. By 22 April 2026, virtually all SSAP and one-member executive pension holders must either move to a new structure or make their existing scheme fully IORP II-compliant.

For most small SSAPs, full compliance is simply not economical. Estimates suggest costs of tens of thousands of euro per year for some small schemes. Many people are simply winding up their small SSAP and transferring to an alternative arrangement.

If you do nothing, you risk having your scheme effectively frozen, with no further contributions allowed and very limited investment changes. Trustees may resign, leaving you with a stranded arrangement.

What About Existing Property Holdings?

One of the biggest concerns in the industry is whether any new restrictions will apply to existing holdings or only to future investments. Industry bodies including Brokers Ireland and the Society of Actuaries are arguing strongly for any new restrictions to apply only to future investments, rather than forcing existing property holdings to be sold.

There is also an acknowledgement that direct bricks-and-mortar property may warrant different treatment from other unregulated assets, as its risks are more tangible and easier to assess. However, nothing has been decided yet.

If your pension holds property or similar non-standard assets, you may need to either transfer it to a receiving scheme that will accept it, or sell the asset within your current scheme and transfer the cash proceeds. Commercial property sales can take time, so early planning is essential.

What Should You Do Now?

Given how technical and time-sensitive this area has become, the best course of action is to review your specific structure with a regulated financial adviser who understands the nuances of executive pensions, PRSAs, master trusts and property-held pensions.

You do not have to get everything perfect. Financial health is about progress, not perfection. Small steps, taken consistently, can make a real impact over time.

Getting Financial Advice That Fits Your Life

You have worked hard to build your future. Now it is time to make the most of it.

With pension rules changing rapidly and compliance deadlines approaching, there has never been a more important time to take control of your financial plan. Whether you are a business owner, a senior executive or planning your next chapter, you deserve advice that is tailored to your goals.

At Lynx Financial Services, we keep things simple. No complicated jargon. Just clear, practical guidance to help you plan your pension, manage your investments and protect your future.

Because good advice is never one-size-fits-all. It is built around you.

📩  Call us today for a no-obligation chat or connect with Gareth on LinkedIn.

 

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