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Public Policy Bulletin, 8 March 2024

Mar 07, 2024
In this month’s public policy update, our policy team outlines its ongoing lobbying efforts on the issue of childcare, its representations to Government on how a change in process is impacting Critical Skills Employment Permit holders and the Institute’s recent submission to the Department of Social Protection on pensions auto enrolment.

Advocating for improved childcare in the Republic of Ireland and Northern Ireland

Following the publication of our recent policy paper Supporting Working Parents – The case for better childcare policy in the Republic of Ireland and Northern Ireland, efforts have been ongoing to engage with policymakers across the island of Ireland on this important issue. Last week, our public policy team met with officials from the Department of Children, Equality, Disability, Integration and Youth to discuss our members feedback on the issue and in particular to emphasise the need to improve capacity across the sector. Meetings have also been held with opposition parties on the issue including Sinn Fein so as to ensure our members voice is heard across the political spectrum.

Following the restoration of the Northern Ireland Assembly, meetings have also been held with legislators from all political parties as work toward developing a new childcare strategy for the region advances. As part of these discussions, our policy team have emphasised the cost pressures our Northern Ireland members are facing with respect to obtaining adequate childcare and in particular the need to abolish the £10,000 cap on tax-free childcare.

Our policy team will continue to advocate on the issue of childcare throughout the year and welcome members feedback on the issue which can be sent to publicpolicy@charteredaccountants.ie.

Changes with Critical Skills Employment Permit / Stamp 4 process causing issues for member firms

Following recent changes announced by the Department of Enterprise, Trade and Employment (DETE) on November 15 2023, holders of Critical Skills Employment Permits (CSEP) must now apply directly to the Department of Justice or their local immigration office (if living outside Dublin) for a Stamp 4 permission to continue to reside and work in Ireland following the expiration of their CSEP.

To obtain a Stamp 4 on or after the 30 November 2023, CSEP holders must complete a minimum of 21-months' work following the issuance of a Stamp 1. In effect, this means that the eligibility to meet the 21-month test does not start from the day the worker started to work physically in Ireland (which was the case under the previous system); instead, the clock starts from the date the Stamp 1 is issued (which could be several weeks later).

These changes have had an enormous impact on CSEP holders and their employers, who in many cases bear the financial cost of the visa application process on behalf of their employees. Specifically, given that the 21-month period required to apply for a Stamp 4 is now only deemed to have commenced after the CSEP holder obtains a Stamp 1, many CSEP holders are finding that their 2-year CSEP expires before they have met the 21-month period needed to obtain a Stamp 4. This is the result of extensive processing times, with some employees reporting up to 18 weeks wait for Stamp 1 applications, particularly in regional areas. Such employees cannot possibly meet the 21-month period before their CSEP expires, as they are not able to obtain their Stamp 1 within the parameters of their CSEP. As a result,  many member firms have reported the need to apply for a ‘bridging’ CSEP to cover these employees until they can meet the necessary 21-month residency period, which in turn has created additional financial and administration costs.  

Our policy team have written to officials in both the Department of Justice and DETE to highlight this issue and to request a meeting to discuss how the new system may be adjusted to reduce the financial and administrative burden it has placed on our members.

Representations to Government on Pensions Auto Enrolment

The Institute’s policy team have also recently written to the Department of Social Protection on the need to allow businesses adequate time to plan for the introduction of pensions auto-enrolment. While the Institute has long been clear in our support for the introduction of auto-enrolment as a mechanism for increasing private pension coverage in the State, payroll services providers tell us that a lead-in time of at least 18 months would be required to properly adapt to this significant change. In order for auto enrolment to be a success, we are calling on the Government to adopt the recommendation of the Joint Committee on Social Protection (in its pre-legislative scrutiny report) that there be a two-year lead-in period, following the relevant legislation being signed into law, that allows businesses time to adequately prepare for the implementation of auto enrolment.

In addition to the above, the policy team re-emphasised the Institute’s position that any new scheme of auto-enrolment should facilitate the existing and well established model of tax relief at both standard and marginal rates for pension contributions, rather than introduce a new scheme of tax relief, as proposed.

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