ARTICLE
2 October 2025

Charting A Course To Auto-Enrolment: Key Dates For Employers

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William Fry

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William Fry is a leading corporate law firm in Ireland, with over 350 legal and tax professionals and more than 500 staff. The firm's client-focused service combines technical excellence with commercial awareness and a practical, constructive approach to business issues. The firm advices leading domestic and international corporations, financial institutions and government organisations. It regularly acts on complex, multi-jurisdictional transactions and commercial disputes.
At the Irish Association of Pension Funds Investment Conference in September, an official from the Department of Social Protection...
Ireland Employment and HR

At the Irish Association of Pension Funds Investment Conference in September, an official from the Department of Social Protection (Department) provided a detailed update on the rollout of auto-enrolment (AE) in Ireland and the commencement of My Future Fund.

The Department confirmed its plan to issue the first AE Payroll Notifications (AEPN) in early December 2025 based on a 13-week lookback covering payroll data during September, October and November 2025. This is a critical milestone ahead of the "go-live" date of 1 January 2026, when contributions to My Future Fund will commence.

Key Dates

The Department indicated that the key dates for the launch of the AE system are:

Timeline
September 2025 13-week lookback commences
October 2025 Testing the AE system with live Revenue data
Late October/November (After the Budget) Member charges and member fees are likely to be announced
December 2025 Employers to register on the employer portal
December 2025 First AEPNs to be issued to employers
1 January 2026 "Go-live" date for the first contributions to My Future Fund.

What Employers Need to Know

AEPNs

The authority responsible for the AE system, NAERSA, will use payroll data from Revenue to determine which employees are in scope, looking back over a period of 13 weeks. If an employee is deemed to fall within AE's scope, an AEPN will be issued to the employer.

The Department has noted that employers should expect the first AEPNs in early December 2025, allowing time to integrate with payroll systems ahead of January 2026. As the first AEPNs are set for early December, this initial 13-week lookback will capture September, October and November 2025 payroll data. Employers looking to operate a single scheme approach will need to ensure all employees are enrolled in their current pension arrangement by November 2025 at the latest.

Employer Portal Launch

The Department will launch an employer portal (Employer Portal) for the AE system, which is expected to occur in early December. Once launched, employers will be asked to register on the Employer Portal to provide their company details and payment details for future contributions.

Payroll Systems Engagement

The Department confirmed that engagement with payroll software providers and Revenue is ongoing. Employers should liaise with their payroll providers to confirm their system is compatible with how AE will operate in practice.

Member Charges and Fees Announcement

The Department intends to submit a comprehensive memo covering all aspects of the My Future Fund cost structure, including the member fee framework, to the Government in the coming months. Once approved, this information will be publicly shared before 1 January 2026.

Next Steps

The next few months will be critical as the AE system moves into implementation. With AEPNs due to issue in early December and the first contributions due from 1 January 2026, proactive preparation is essential to ensure compliance with the new requirements.

To prepare for the launch of AE, employers should:

  1. Review Payroll Data: Ensure all employee records are accurate and current for the 13-week lookback period.
  2. Decide on their planned approach: Decide whether they wish to encourage enrolment into their current pension arrangement (a single scheme approach) or operate a dual scheme approach with some employees in the AE system and others in the company pension arrangement.
  3. Engage with their Advisers: Having decided on their planned approach, employers should engage with their advisers to implement this approach promptly.
  4. Engage with Payroll Providers: Confirm that payroll systems are ready to support AE instructions and contribution processing.
  5. Prepare for Registration: Be ready to register on the Employer Portal once available.

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.

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