Yeah, I also would think it would depend on the species of turtle.
I didn't think Ireland got much in the way of hard, long term, freezes. Koi will certainly be able to handle ice for short periods. If you were to add a heater thinking 40F was too cold, and instead kept the water in the 45-50F range you would be keeping aeromonas bacteria going while shutting down the Koi's immune system. Most people try to avoid that. I assume Ireland has aeromonas bacteria and if not, other harmful bacteria.
I would also be a bit wary about being overly concerned with keeping an open in the ice. There are down sides to this. Keeping an opening drops the water temperature. If you're looking at weeks or months of ice then gas exchange might be a larger risk than the lower water temp. Has to be each ponder's call.