As the professional standards body for financial planning in Ireland, our response is intentionally focused on matters within our remit, particularly the role of high quality financial planning and access to professional advice in supporting good retirement outcomes.
FPSB Ireland broadly supports ISD as an additional retirement option, provided it complements rather than replaces existing options such as annuities, ARFs and vested PRSAs, and does not introduce unnecessary complexity into the retirement landscape.
The submission centres on three core messages:
1. The importance of regulated financial advice
Retirement drawdown decisions are complex, ongoing and often irreversible. We emphasised that access to regulated financial advice at retirement, and throughout retirement, is critical to achieving positive client outcomes. Generic disclosures and digital tools cannot substitute for personalised, professional advice.
2. The need for holistic financial planning
Decisions around ISD must be considered in the context of a client’s broader financial circumstances, including other retirement assets, income sources and taxation considerations. This reinforces the importance of comprehensive, client centred financial planning, which is the core expertise of CFP professionals.
3. Access to advice and clarity for trustees
We recommended that members should have the option to pay for regulated financial advice from pension scheme assets where they choose to do so. We also called for legislative and regulatory clarity to ensure trustees can facilitate access to advice without assuming responsibility for the advice provided.
We deliberately did not comment on scheme design, pricing or operational trustee matters, as these fall outside our area of expertise.
Our concluding position is clear. While we support the introduction of ISD, its success will depend on strong facilitation of professional financial advice, alignment with existing retirement options and appropriate consumer protection.
The consultation represents an important development in the retirement landscape. FPSB Ireland will continue to advocate for the role of CFP professionals and the value of rigorous professional standards in supporting consumers through complex retirement decisions.