IAPF Submission to Department of Social Protection: Auto-Enrolment Implementation Regulations

The Irish Association of Pension Funds has submitted a detailed response to the Department of Social Protection's consultation on the draft regulations governing the rollout of Ireland's auto-enrolment retirement savings system. The submission welcomes the broad framework established by the Automatic Enrolment Retirement Savings System Act but raises a number of practical concerns that the IAPF believes must be addressed before the system goes live.

Chief among these is the treatment of employees who are already members of qualifying occupational pension schemes. The IAPF argues that the current drafting creates unnecessary uncertainty for employers who operate well-governed defined contribution schemes that meet or exceed the auto-enrolment contribution minimums. The submission calls for clearer statutory criteria for qualifying scheme exemptions, and for the Pensions Authority to publish definitive guidance on the approval process well in advance of the enrolment date.

The IAPF also raises concerns about the administrative burden placed on small and medium employers, many of whom lack dedicated HR or payroll infrastructure to manage the enrolment, opt-out and re-enrolment cycle. The submission recommends that the Central Processing Authority provide a standardised employer toolkit and a dedicated helpline during the initial rollout period.

On contribution phasing, the IAPF broadly supports the gradual approach but recommends that the government commission an independent adequacy review within five years of the system going live, to assess whether the ultimate contribution rates are sufficient to deliver meaningful retirement income for low and middle earners.

The full submission is available to download in the IAPF publications library.