The Minister for Social Protection, Dara Calleary T.D. (Minister), recently announced a delay in the rollout of Ireland's Automatic Enrolment (AE) Retirement Savings System, also known as "My Future Fund".
Under secondary legislation, 30 September 2025 has been set as the date from which employer obligations under the Automatic Enrolment Retirement Savings System Act 2024 (AE Act) would take effect. As such, it is expected that replacement secondary legislation will need to reflect the new "go live" date.
The National Automatic Enrolment Retirement Savings Authority (NAERSA) is still in the process of being established, with the role of CEO for the new State body having been recently advertised. In the meantime, the Department of Social Protection (DSP) is charged with the preparatory work for AE, including running awareness campaigns. The DSP has also just announced that Irish Life Investment Managers, Amundi and Blackrock were selected as the preferred bidders for providing investment management services to the AE system.
What Does This Mean for Employers?
The postponement means enrolment of in-scope employees (and payment of related contributions) to the AE system is now set to begin in January 2026. Employees will be automatically enrolled into the AE system by the NAERSA if they: (i) are aged between 23 and 60; (ii) earn gross pay from all employments of €20,000 or more per year; and (iii) are not exempt from AE. Employees will be exempt from AE if employee and/or employer contributions are made via payroll to a Personal Retirement Savings Account (PRSA) or pension scheme.
Employers who have not yet decided on an AE strategy now have more time to consider what approach suits their business.
Employers who currently offer a contributory pension scheme or PRSA (Workplace Pension) face an important decision: They must choose between a "single-scheme" approach (adapting their current Workplace Pension to position all employees as exempt from AE) or a "dual-scheme" approach, where the existing pension continues and employees who are not members of the Workplace Pension are automatically enrolled in My Future Fund. Employers will need to assess which option works best for their workforce.
Key Next Steps for Employers
In our last article on the topic, we outlined preparatory steps employers could usefully take ahead of AE's "go-live" date, which we briefly recap below:
- Identify employees within the scope of AE: Employers should assess who in their workforce will be in-scope of AE. This "in-scope" analysis is something employers will need to carry out to enable them to budget for AE's costs ahead of January 2026.
- Assess the costs and administrative issues: Employers should consider the administrative and financial implications of adopting either a single-scheme or dual-scheme approach. Employers need to understand the potential costs and the systems required to manage both options. One possible drawback (amongst others) to the dual-scheme approach is the possible administrative burden of operating two differently structured pension savings systems in the same workplace. However, there are many more factors to consider, and the right decision for each employer will be workforce/business-specific.
- Consider employment law implications: The AE Act does not provide employers with the statutory power to enroll employees into their existing Workplace Pension to address AE compliance. If an employer follows a single-scheme approach, the employment law implications of contractually auto-enrolling current and future employees into an existing Workplace Pension must be carefully considered.
- Employee relations considerations: There is a risk with the dual scheme approach of creating a "two-tier" system of pension benefits within the one workforce. AE might be perceived as a lesser value offering with a possible latent employee relations risk. This risk will need to be managed by clear and effective communication to ensure that all employees understand their options. Engaging with employees early on those options and answering any concerns will be key to a smooth transition.
- Benefit design changes to existing pension arrangements: For employers who wish to use their existing Workplace Pension to comply with AE, amendments may be required to the current offering to tailor it to AE. For example, an existing Workplace Pension that operates voluntarily or imposes a waiting period before employees become eligible to join may need amendments to ensure eligible employees are automatically enrolled upon starting employment.
- NAERSA Employer portal: The DSP has confirmed that NAERSA will establish an employer portal by the end of 2025. Once that portal is available, employers will need to register regardless of whether they intend to take a single-scheme or dual-scheme approach.
As the launch of My Future Fund draws nearer, the delay provides employers with valuable additional time to prepare for the changes ahead. By addressing the considerations outlined above, employers can ensure they are well-positioned to navigate the implementation of AE in 2026.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
