“Auto Enrolment has been talked about for decades – now it is finally happening.” The words of Social Protection Minister Heather Humphreys after the Automatic Enrolment Retirement Savings System Bill passed through the Houses of the Oireachtas.
Ireland is one step closer to catching up with every other OECD country that already has some form of auto-enrolment. It might be finally happening, but when is less clear. Momentum is needed to avoid the work of the last two decades being squandered.
Two-thirds of Chartered Accountants Ireland’s members work in business, many of whom will be required to put such a scheme in place for their employees. The most recent formal communication from government suggests a start date sometime in 2025.
And yet, putting in place the infrastructure to facilitate a system of pensions auto-enrolment is a mammoth task, and the list of outstanding deliverables at Department level is concerning before it even comes time for businesses to act.
Hurdles to clear
The legislative hurdle has now been cleared, but the Department of Social Protection has only in recent weeks appointed a company to build and run the new system. We are encouraged to see they have chosen a company that has a record of success in building the UK equivalent. We urge the Department to now expedite the appointment of a firm to manage the underlying investments.
In recent weeks, it was reported that the Department of Finance has raised concerns that the auto enrolment legislation has been framed in a way that will force the regulator to apply a lower standard of oversight than that imposed on firms in the private pensions market.
Other details also need to be clarified. In recent months, this Institute has requested such clarity in several areas. Many employers with staff who are likely to come within the remit of auto-enrolment will already have occupational pension schemes in place. To avoid the administrative complexity of setting up and operating a second staff pension scheme under auto enrolment, such employers may instead offer to extend participation in their current pension scheme to currently non-pensionable employees.
However, if even just one of these employees refused to join the staff scheme in favour of being automatically enrolled, the employer would still be compelled to undertake the cost of setting up and operating a second scheme.
We also sought more information around the meaning of “employee”, defined in the legislation as “a person in receipt of emoluments”. Such a definition would extend to individuals already in full-time pensionable employment who also undertake additional work who will therefore be required to contribute to a second pension scheme.
Communication is going to be key
The government’s recent SME package put a premium on the importance of consultation and dialogue with SMEs and other groups before introducing new legislation or policy affecting them. Auto enrolment is an opportunity to put this into practice. The government now needs to publish a road map and stick to it.
While feedback was invited as part of an initial public consultation in 2018, since then only a very basic four-page guidance note for employers has been issued by government. To gain and maintain momentum, extensive and continuous stakeholder engagement is needed - not least with employers and payroll providers, upon whom the successful operation of the new system will be largely dependent.
In a survey of small businesses conducted by Chartered Accountants Ireland, almost 90% felt that businesses had not been adequately informed of the steps needed to be taken by them to comply with pensions auto-enrolment in time for an early 2025 start date. Interestingly, three quarters of those surveyed will be required to introduce the new pension scheme, and for many this will be alongside their existing occupational pensions.
Businesses need to see what the journey to implementation will look like. In a high-cost environment, this will give much needed reassurance and help to allay concerns.
What is a realistic timeline?
In its pre-legislative scrutiny report on the Bill introducing auto-enrolment, the Joint Committee on Social Protection recommended a two-year lead-in period, following the Bill being signed into law, to allow sufficient time for implementation.
Payroll providers have been consistent in highlighting the need for an initial pilot phase to facilitate testing of the new system and to allow sufficient time to assimilate auto enrolment with current payroll systems. Neither of these fit into a 2025 implementation timeline.
If officials truly want auto-enrolment to be a success, this timeline should be revisited and a 2026 or beyond start date announced. They may wish to avoid yet another postponement to the launch of auto enrolment but what should really matter here is getting it done right and giving businesses a chance to adapt. This additional time needs to be wisely used, by facilitating ongoing dialogue between departments, third party partners in implementation, and the many business groups and stakeholders who have walked this long road to auto enrolment.
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