The initiative aligns with a September 2025 European Commission recommendation which encourages EU member states to introduce or enhance SIA regimes to tackle structural barriers to retail investment, which include high levels of taxation, complex investment processes, fragmented markets and low financial literacy.
Empowering individuals to make a better use of their savings
Ireland does not have a framework for SIAs but is expected to introduce one in the near term. According to recent policy statements, the government plans to legislate for an SIA framework in 2026 with the intention that SIAs will be available to the public in 2027.
Early indications suggest that the Irish model will prioritise simplicity, accessibility and tax efficiency. Proposals under consideration include a flat‑rate tax applied to the value of assets in the account above a threshold, with providers responsible for administering tax obligations.
Speaking at the inaugural Savings and Investment Forum in March 2026, the Irish minister for finance Simon Harris said Ireland has “a real opportunity to empower individuals to make better use of their hard‑earned savings” and described the proposed personal investment account as potentially “transformative”. He also emphasised the need for simplicity in the tax framework, with SIAs intended to operate based on a single annual flat‑rate tax administered by SIA providers.
A central driver of the proposed regime is the scale of savings held in Irish bank deposits. Irish households are estimated (18-page /780KB PDF) to hold more than €170 billion of cash in bank deposits, a significant proportion of which does not generate any returns for savers. In this context, the government sees SIAs as a mechanism to reallocate a portion of these savings into capital markets, helping households achieve better long‑term returns while also supporting investment in the wider economy.
Policy initiative to unlock retail capital
Under the EU recommendation, the Commission’s policy objective is to improve financial outcomes for individuals by encouraging greater investment in capital markets, and to increase the role of retail capital in financing EU economic priorities. Evidence cited by the Commission suggests that EU households already maintain comparatively high levels of savings, with around €10 trillion in the EU held in bank deposits, but these are often held in low‑return deposits rather than invested assets.
The SIA initiative forms part of the EU’s broader Savings and Investments Union agenda, which seeks to mobilise Europe’s high levels of household savings and channel them into the real economy. By facilitating greater retail participation in capital markets, SIAs are intended to support investment in important sectors, including the digital transition, the green and energy transition, and broader social and strategic priorities across the EU.
To be effective SIAs should be designed as tax‑advantaged investment accounts offered by authorised financial providers, enabling individuals to invest in a range of instruments such as shares, bonds and investment funds. SIAs should be simple to set up and operate.
Features of the proposals
The EU recommendation sets out a detailed framework for national SIA regimes, drawing on best practices across existing models. Member states are encouraged to adopt core features designed to maximise accessibility and retail investor uptake, which include:
- No minimum investment thresholds: SIAs should be accessible regardless of investors’ financial capacity;
- Simple, transparent cost structures: the fees, costs and charges of SIAs should be proportionate and easy to compare;
- Portfolio flexibility and portability: transfers between SIA providers should be streamlined and should not trigger adverse tax consequences;
- Wide but appropriate investment scope: investors should have access to diversified portfolios, at a minimum including shares, bonds and UCITS funds, while excluding highly complex or risky products;
- Broad provider access: SIAs should be offered by a wide range of authorised firms, including cross‑border providers operating under EU passporting rights;
- Optional advice models: investors should be given the opportunity to choose between advised SIAs and execution‑only services.
What retail participation looks like
Experience from other jurisdictions illustrates how SIAs have been successful in raising investment from retail investors.
For example, the UK’s stocks and shares individual savings account (ISA) provides retail investors with a straightforward, tax‑advantaged wrapper through which they can hold shares, funds or ETFs with clear visibility on holdings, value and charges. Similarly, Sweden’s ‘investeringssparkonto’ (ISK) model applies a simplified taxation approach based on the value of the account rather than realised gains, combined with direct ownership of underlying instruments and low administrative complexity. These examples demonstrate how SIA frameworks can combine simplicity, tax efficiency and broad investment access to drive high levels of retail participation.
Laying the foundations for a pan-European market in SIAs
A core element of the Commission’s recommendation is that SIAs should be capable of being offered on a cross-border basis throughout the EU. Accordingly, member states are expected to ensure that financial service providers authorised in one member state can provide SIAs in another without additional local requirements, in line with the principles of freedom to provide services and freedom of establishment under EU law.
The recommendation makes clear that national SIA regimes should not create any barriers to the cross-border provision of financial services or the free movement of capital. Providers authorised elsewhere in the EU should therefore be permitted to offer SIAs under the same conditions as domestic firms.
To facilitate the cross-border functioning of SIAs, the recommendation emphasises the need for transfer mechanisms that allow portfolios to be moved between providers, including across member state borders, without triggering tax consequences or creating unnecessary administrative burdens. Transfers should not result in a taxable event or the loss of any associated tax or regulatory benefits. This approach supports seamless portability, enabling investors to switch providers with minimal friction and reinforcing the Commission’s broader objectives of promoting competition, investor choice and pan‑European integration in capital markets.
Taxation of SIAs
The success of the proposed SIA will largely depend on the delivery of a clear, consistent and competitive tax framework that aligns with international best practice.
Current Irish tax rules, such as the comparatively high effective tax rates on investment returns and the rules on deemed disposals by investors in investment funds and life assurance (unit-linked) investment products, are material deterrents to retail participation.
In relation to the design of SIAs, the Commission encourages member states to introduce preferential tax regimes that will be beneficial for SIA holders and will incentivise their uptake with features such as: tax deductions where an amount invested in an SIA may be deducted from an investors taxable income; tax exemptions where income generated in an SIA is tax exempt or; tax deferrals where income tax on a SIA is deferred until cash is withdrawn from the SIA.
The government’s framework has not yet been announced; however, it is expected to feature an annual flat rate tax, likely to be set in the budget later in 2026. It is understood that the flat-rate tax will be applied to the value of assets held in the account above a tax-free threshold.
Importantly, providers of SIAs are expected to administer the tax on accounts. This will require the implementation of processes for the collection of tax and reporting tax information to the Revenue Commissioners.
Getting ready for the opportunities that SIAs present
Firms offering SIAs should implement appropriate onboarding, disclosure, client acknowledgement, transaction reporting and record-keeping processes and ensure clients are appropriately classified so that the firm complies with its requirements in relation to suitability and appropriateness of the SIAs offered to clients.
If a firm provides advice to clients in relation to the SIAs that it distributes, it will be subject to detailed investor protection requirements. The main obligations include:
- Conducting a suitability assessment to determine if the SIA is suitable for the client. The suitability assessment should cover the client’s knowledge and experience with the relevant investments, the client’s financial situation – including their capacity and ability to bear financial loss – and investment objectives, including risk tolerance. Where sufficient information is not obtained, firms must warn the client that suitability cannot be assessed and must not make a recommendation;
- Delivering a suitability report to the client prior to opening the SIA account and before any investment is made. This should include a statement explaining how the recommendation concerning the SIA meets the client’s preferences, objectives and characteristics;
- Assessing a sufficiently broad and diverse range of investment accounts where independent advice is provided, supported by a clearly defined advice universe and not limited to proprietary or closely linked products.
Given the operational and compliance burden, firms must assess at an early stage whether providing independent advice within an SIA model is commercially viable.
SIA providers are also subject to product governance obligations, which require firms to:
- Define a target market for each SIA account or variant thereof, including the intended client type, risk profile and investment objectives;
- Ensure that the design of the SIA product aligns with the needs, characteristics and objectives of the identified target market and that products are regularly reviewed taking into account potential risks to that target market are assessed;
- Establish distribution strategies that are consistent with the identified target market and regularly assess whether the SIA accounts are being distributed appropriately and in line with the target market;
- Conduct ongoing product reviews to assess whether the SIA accounts continue to meet their intended objectives and to identify any need for adjustments or remedial action and take steps where products are distributed outside the target market;
- Operate a formal product approval process prior to marketing and make appropriate information available to distributors; firms distributing products must obtain sufficient information to understand the product and target market.
These governance requirements oblige firms to maintain a structured oversight framework throughout the product lifecycle, including ongoing monitoring and review of distribution and product performance.
SIA costs and charges
The cost profile of SIAs is expected to mirror that of established European equivalents, such as UK ISAs and Swedish ISKs. Investors should expect a combination of: platform fees of up to approximately 0.5% per annum, and; ongoing charges on underlying investments, typically up to approximately 1% per annum for index-tracking funds.
In addition, any annual tax charge will represent a further drag on performance. When these elements are considered alongside prevailing inflation, which are currently in the region of 3% per annum, they imply a combined hurdle rate of approximately 5.5% per annum. Investment performance will therefore need to exceed this level in order to preserve capital and achieve real growth over time.
Our view
A report published by Banking & Payments Federation Ireland estimates that the amount of investment in SIAs could reach €7 billion within the first 12 months, which highlights the commercial opportunities in the market for SIAs in Ireland.
Ireland’s planned framework, which is aligned with the European Commission’s recommendation, has the potential to fundamentally reshape the retail investment landscape by directing household savings into capital markets and widening access to investment products. The success of SIA products in Ireland will depend on resolving core issues, most notably the tax framework, and on the ability of providers to deliver products that are low cost, simple understand and operate, and that deliver value for money for end investors.