What should pension scheme trustees do now to stay DORA ready

In April 2026, the Pensions Authority issued an update on Registers of Information (ROIs) under the Digital Operational Resilience Act (DORA). The update reflects EU changes to the way supervisory authorities collect ICT outsourcing data. It confirms that the first formal ROI submission for Irish pension schemes has been deferred until 2028.

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.

Summary of key takeaways for trustees:

• The first formal ROI submission for pension schemes is deferred until 2028.
• The core obligation to maintain an accurate and up‑to‑date ROI continues to apply.
• ROIs must be updated on change and reviewed and evidenced at least annually.
• A full, structured ROI will be required by reference to 31 December 2027.
• Trustees should use the deferral to strengthen governance and data quality.
• Deferral should be treated as preparation time, not a relaxation of supervisory expectations.

For information on how ALG can assist you in relation to DORA compliance for pension schemes, please contact David Francis, Partner, Ciara Brady, Senior Associate or your usual ALG contact.

Date published: 19 May 2026