Pensions Board chief executive Brendan Kennedy said the fines, expected to be 2,000 per violation when they come into effect at the end of the year, would not be applied without discretion or for simple mistakes, as trustees had feared.

"We're reasonable people, we have better things to do than trap trustees, " he said.

"If someone genuinely has discovered an accident, we'd find it difficult to decide to go through with the full vigour of the law. We're not going to prosecute trustees for being two days late with their annual report."

The fines, he said, are designed to deal with minor violations for which criminal prosecution . . . currently the only recourse for the regulator . . . was inappropriate.

The Pensions Board is planning a publicity campaign later this year, ahead of the introduction of fines.

Trustees will get a checklist of their obligations under the Pensions Act.

"All trustees need to do is go to their pension company and check against the list, " Kennedy said. "If they can demonstrate they've taken reasonable steps, they'll be okay if there's a problem."

The chairman of the Irish Association of Pension Funds, Joe Byrne, said last month that a rigid approach to stewardship of company pensions could disincentivise trustees and suppress voluntary compliance when problems do arise.