The Institutions for Occupational Retirement Provisions Directive II (‘IORP II’) [], was effective from the 13th January 2019. The original Directive required all Occupational Pension Schemes with over 100 members to be regulated by the Gibraltar Financial Services Commission (‘GFSC’). IORP II introduces a registration requirement for all schemes that have between 15 and 100 Members and calls for such schemes to comply with certain requirements. This means that many more schemes will now fall under the GFSC’s remit.  Note that the number of Members mentioned above also includes Deferred Members.

The GFSC is setting up a Working Group to further discuss the implementation of IORP II in Gibraltar.

Update for IORP and its Advisors

We have written to all known firms that provide services to Occupational Pension Schemes in Gibraltar in a Trustee, Administrator and/or Advisory capacity.   In order for the GFSC to better understand the impact of IORP II and to enable us to advance our preparatory work, we need to collect data regarding Occupational Pension Schemes in the jurisdiction.

Who's Caught

Firms impacted by this Directive include those that offer or may have offered an occupational pension scheme for its employees. One of the main aspects of IORPS II is the application of the legislation to occupational pension schemes with fifteen or more members. Members include both active and deferred members, as well as members receiving pension payments. Further information and FAQs can be found here.

Firms with schemes that may be caught by this Directive should contact us on as soon as possible. 

IORP – Actions:

Any IORP who are now caught by IORP II as a result of the reduction in number of Members should contact the GFSC at the earliest opportunity. Please email