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Update on the Government’s Auto-Enrolment (AE) Pension Scheme

By Brian Mulcair | July 24, 2024

WTW provides important update on the Government’s Auto-Enrolment (AE) Pension Scheme which has now passed the primary legislation.
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The Irish Government has now passed the primary legislation to implement its Auto-Enrolment Pension Scheme (“the Government AE Scheme”) to help employees who are not already in a company pension plan, save for retirement and simplify the process for businesses who currently do not offer pension plans to their employees.  WTW has created a guide which provides employers with an overview of how the new AE Scheme will operate and the preparation steps that employers should take in advance of the AE Scheme going live. 

The AE Scheme is designed to boost retirement savings amongst workers from a position where just 35% of private sector employees currently have supplementary retirement savings.

What are the key features of the Government's AE scheme?

The AE Scheme is a defined contribution pension scheme where employees’ contributions are matched by their employers, supplemented with a top-up from State funds. The information below summarises the key features of the scheme.

Eligibility

All employees aged 23 to 60 earning over €20,000 annually across all their employments, will be automatically enrolled into the AE Scheme. However, employees for whom contributions are being paid to an employer pension plan will be excluded.

Employees outside the age and salary criteria can opt-in.

NAERSA will issue notifications to employers in respect of any employees who must be enrolled in the AE Scheme, which will include employees on probation, part-time, or casual contracts.

Contributions

  • Employee and employer contributions to the AE Scheme will start at 1.5% of gross income, increasing every three years to reach 6%.
  • The State will contribute an additional €1 for each €3 of employee contribution
  • An Earnings Cap of €80,000 will apply for contribution purposes.
  • The overall contributions are summarised in the following table:
Contribution Design
Overall contribution design and allocation from employee, employer and Government to the new AE Scheme
Years / rates Employee* Employer Government Total
2025 – 2027 1.50% 1.50% 0.50% 3.50%
2028 – 2030 3.00% 3.00% 1.00% 7.00%
2031 – 2033 4.50% 4.50% 1.50% 10.50%
2034+ 6.00% 6.00% 2.00% 14.00%

*It is important to note that the employee’s contribution will be deducted from their after-tax pay. The eventual 6% employee rate is therefore equivalent to contributions of 7.5% and 10% of gross pre-tax earnings for standard rate and top rate tax-payers respectively.

Opting Out

  • Employees will be able to opt out of the AE Scheme at certain points, mainly six months after joining the AE Scheme and six months after a step up occurs in contributions to the AE Scheme.
  • Any employee who opts out will be re-enrolled again after two years and they can opt out again after another six months. Upon opting out, they will receive a refund of their contributions while employer and State contributions will remain in their AE Scheme retirement account.
  • Employees will also be able to pause contributions after six months, subject to certain conditions.

Accessing Benefits

Employees will have to wait until they reach the State Pension Age of 66 before they can access their benefits under the AE Scheme. While initially retirees will be able to draw their benefits as cash, the precise options applying on retirement in the medium to long term have yet to be developed. However, the options are expected to be similar to those available to members under company DC plans.

Fund Choices

Employees will be able to choose from four retirement savings funds, based on their risk tolerance: a Conservative fund, a Moderate risk fund, a Higher risk fund, and a default Lifestyle/Life-cycle fund if no preference is expressed.

Changing employment

The AE Scheme retirement saving account will be allocated to the individual throughout their career. This means that if an employee leaves an employment that was utilising the Government AE Scheme and joins a new employment that also uses the Government AE Scheme then contributions under the new employment will commence into the same AE Scheme account. We refer to this as “pot follows member”.

How does the Government AE Scheme compare with employer DC Plans?

There are a number of significant differences between the AE Scheme and occupational pension schemes which are summarised on the following table:

Comparison of Government AE Scheme and Employer DC Plan

The differences between the AE Scheme and occupational pension schemes
Government AE scheme Employer scheme
Set contribution rates and €80,000 earnings cap Significant contribution flexibility
Government top-up incentive (€1 for €3 of employee)equivalent to 25% tax relief Marginal income tax relief (0%, 20% or 40%)
Low, medium and high-risk funds with default lifestyling Typically, wide range of investment funds
Can’t access benefits until State pension age (66) Can access benefits from age 50
Retirement account follows member Retirement account stays in employer plan by default

The Government AE Scheme is quite inflexible in many ways. For example, there is no ability for employees or employers to pay higher levels of contribution to the AE Scheme so the maximum contributions in the first 3 years will be 1.5% employee / 1.5% employer. Many employees and employers may desire to pay higher contribution amounts than this to provide for their retirement.

There will also be quite a restrictive range of investment funds available compared to those typically available under an employer DC Plan. Finally, there will not be the ability to access benefits before age 66 (save for the circumstances of severe ill health).

There has been significant discussion and debate around the different incentives under the Government AE Scheme (€1 top up for every €3 of employee contribution) versus DC pension plans (income tax relief at source). Below we examines the ratio of the total contributions paid into an employee’s retirement account under the Government AE Scheme and an employer DC Plan for each €1 of after-tax member contribution.

Ratio of the Total Contributions

Examines the ratio of the total contributions paid into an employee’s retirement account under the Government AE Scheme and an employer DC Plan for each €1 of after-tax member contribution.
Government AE Scheme DC Plan (20% tax payer) DC Plan (40% tax payer)
€2.33 €2.50 €3.33

This analysis assumes that the employee contribution is matched under the DC Plan on a one for one basis (this is typical and in some plans the ratio is higher).   This demonstrates that existing DC Plan are typically more advantageous for employees and significantly more so for higher rate taxpayers.

How Can We Help?

At WTW, we are committed to guiding your business through the upcoming changes being introduced under this Government AE Scheme.   We have established a new specialist AE team dedicated to assisting all our clients and we offer a two-phase service to ensure that your company adopts the correct AE strategy and then implements that strategy and communicates effectively with employees in advance of the new AE regime going live.

Phase One: AE Strategy Report

  1. Standard Data Request
    • We will provide a standard data request form for you to complete, gathering basic information about your current employee demographics, and some other relevant details.
  2. Comprehensive AE Report and Consultation
    • Using the data we will prepare a tailored report that will provide you with a thorough understanding of the new AE requirements, highlight potential implications for your business, and offer strategic insights to help you proactively plan for the AE go-live date. The report will also cover critical areas such as your existing scheme rules, employee eligibility, contribution structures, and potential cost impacts on your business.
    • This service includes the preparation of a detailed AE report and attendance at a meeting with your team to present our findings and recommendations.

Phase Two: Implementation, Communication, and Rollout

Implementation Planning

  • Customised Implementation Plan: based on our findings from Phase One, WTW will help you develop a customised implementation plan tailored to your business needs. This plan will outline the necessary steps and timelines to ensure compliance with the new AE legislation.
  • Ongoing Support: our team will be available to assist you throughout the implementation process, offering guidance and expertise to address any challenges that may arise.

Employee Communication Plan

  • Clear and Effective Communication: we understand the importance of clear communication to ensure your employees are informed and engaged. WTW will help you design and execute a comprehensive communication plan that includes information sessions, educational materials, and regular updates.
  • Employee Engagement: Our approach focuses on engaging your employees, helping them understand the options available to them and promoting your company pension plan.

Contact us for support

For more information and to get started, please contact your scheme consultant today or submit a contact us form and we will reach out to you immediately.

Author


Head of Corporate Consulting

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