Hard Brexit Impact Analysis

Page 69 of 106 Category If no agreement is reached: Consequence EU Document Pensions As of the withdrawal date, IORPs registered or authorised in the United Kingdom will have to comply, with regard to activities related to EU 27 members and beneficiaries, with the rules of the host Member State applicable to activities of IORPs registered or authorised in a third country. These rules may require a registration or authorisation by the relevant competent authority of the host Member State in accordance with the applicable national rules. WITHDRAWAL OF THE UNITED KINGDOM AND EU RULES IN THE FIELD OF INSTITUTIONS FOR OCCUPATIONAL RETIREMENT PROVISION Pensions IORP registration or authorisation does not grant the right to conduct business across the EU Member States, but is limited to the Member State that has granted the registration or authorisation. WITHDRAWAL OF THE UNITED KINGDOM AND EU RULES IN THE FIELD OF INSTITUTIONS FOR OCCUPATIONAL RETIREMENT PROVISION Pensions Before the withdrawal date, IORPs registered or authorised in the UK which are active cross-border in the EU 27 should contact the competent authorities of the relevant host EU 27 Member States to determine whether and under which conditions they might be allowed to continue their activities pursuant to national law in this Member State. If the Member State allows continued cross-border activities under its national law, the IORPs would have to decide whether to rely on these rules or to transfer the portfolio. People and businesses whose pensions / schemes are vested in a UK established IORP should enquire as to the impact on their rights, entitlements and protection before and after the withdrawal date WITHDRAWAL OF THE UNITED KINGDOM AND EU RULES IN THE FIELD OF INSTITUTIONS FOR OCCUPATIONAL RETIREMENT PROVISION Pensions Transfer to and EU IORP: If it is not possible to continue the cross-border operations into an EU 27 Member State, UK IORPs may decide to transfer their portfolio related to EU 27 members and beneficiaries to a receiving IORP registered or authorised in EU 27, in order to keep such members and beneficiaries under the EU IORP framework. WITHDRAWAL OF THE UNITED KINGDOM AND EU RULES IN THE FIELD OF INSTITUTIONS FOR OCCUPATIONAL RETIREMENT PROVISION Pensions NO Transfer to an EU IORP: If a transfer is not performed, the UK IORP will no longer be able to continue to operate the pension schemes of its EU 27 members and beneficiaries, and the consequences for its EU 27 members and beneficiaries WITHDRAWAL OF THE UNITED KINGDOM AND EU RULES IN THE FIELD OF INSTITUTIONS FOR OCCUPATIONAL RETIREMENT PROVISION