The trustees sign it. The administrator holds the evidence.
A pension fund board is accountable for governance, outsourcing oversight, and policy under IORP II, but the administrator, asset manager, and custodian who actually run the scheme hold most of the underlying records. When a supervisor asks the trustees to show their own outsourcing register, the answer often has to be requested from someone else's system first. Our platform gives trustees their own copy: suppliers, governance data, and policy held at the IORP level, with the DORA register built from it directly. IORP II's governance and disclosure obligations, the parts of the rulebook that need judgement, stay with our specialists, working from that same trustee-held data.
Trustees are accountable for records they do not hold.
An IORP's operational capability sits almost entirely outside the IORP itself. The administrator runs the member-benefit and scheme data. The asset manager runs the investments. The custodian holds the assets. IORP II makes the trustee board accountable for the outsourcing arrangements, the governance system, and the policies that sit over all of it, but the underlying records live in the service providers' own systems.
The practical consequence is that a routine supervisory question, show your outsourcing register, show how key functions are staffed, show the policy that governs this, often means asking the administrator for a file rather than pulling it from the trustees' own records. When the administrator changes, or answers slowly, the trustees are exposed on paperwork they never controlled.
DORA adds a further register on top: ICT third-party arrangements, which overlap heavily with the same administrator, asset manager, and custodian relationships, but under a different criticality test and a different register than the one IORP II Article 31 asks for.
The trustees keep their own copy.
On the platform, the IORP holds its own record: the administrator, asset manager, and custodian as supplier objects in the trustees' own graph, not a request away in someone else's system. The DORA Register of Information reads directly from that graph. Policy generation, with AI-assisted drafting and human approval, gives the board a maintained, versioned policy set rather than a folder of memos.
Governance and role structures sit on the same record: who holds which key function, which supplier supports which scheme function, and what interpretation decisions were made and when. When a supervisor asks to see the outsourcing register mapped to the sub-outsourcing chain beneath it, the answer is already in the trustees' own system.
What this does not claim: the platform does not produce the Own Risk Assessment or the Pension Benefit Statement, and it has no fund or member-benefit schema. Those stay with our specialists and the administrator's own systems, with the platform supplying the governance and supplier data as a shared starting point.
DORA, supplier risk, and policy, held at the IORP level.
When an IORP is onboarded, the platform activates the DORA Register of Information across all fifteen RT/B tables with a submission-ready XBRL-CSV package and GLEIF/LEI verification, scoped to the Article 16 simplified regime where the national competent authority confirms it applies. Supplier risk, the administrator, asset manager, custodian, and their sub-providers, sits in the same graph as first-class objects, with AI-assisted and privacy assessments and contractual arrangements attached.
Policy generation runs in the platform: AI-assisted drafting with human approval for the governance policies the board is required to maintain, version-controlled rather than scattered across advisor correspondence. Governance and role structures capture the key-function holders and their assignments, and every material step moves through a four-eye approval gate.
Our specialists produce the Own Risk Assessment under IORP II Article 28, review the administrator's Pension Benefit Statement production, and document suitability assessments for key-function holders, using the trustees' own supplier and governance data as their starting point rather than the administrator's files.
The scheme-level judgement stays with people who have sat where you sit.
The Own Risk Assessment, the suitability review of key-function holders, and the host-state review for cross-border schemes are judgement calls, not lookups. Our specialists, several former DNB pension supervisors and trustee-board advisors, make those calls using the trustees' own supplier and governance data rather than reconstructing it from the administrator's files.
The reasoning is recorded against the record it concerns, so the trustees have a durable account of every interpretation decision that outlives any single service provider relationship.
You own the platform, the data as adapted to your scheme, and the written record of every interpretation decision. Advisory work on IORP II's governance and disclosure obligations continues for as long as you need it.
A discovery call, not a product demo.
You describe the compliance problem consuming the most of your team's time. We walk the platform through an example close enough to your operation that you can judge whether this way of modelling compliance fits how you want to work.
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