“MyFutureFund” Ireland’s new auto-enrolment pension system is now in effect as of 1st January automatically enrolling “eligible” employees.
While many employers were prepared for this development, what came as a surprise were the further regulations signed into law on 22nd December, 2025 (S.I. No. 668/2025 – Automatic Enrolment Retirement Savings System Regulations (Amendment) (Section 52) Regulations 2025, hereafter the “Regulations”).
The Regulations set out minimum standards that must be met in respect of contributions to occupational pension schemes and PRSAs in order for employments to be “exempt” from autoenrollment to MyFutureFund. These Regulations setting out minimum standards had not been expected for some time.
The Regulations which are already in effect since January 1st stipulate the following minimum standards.
Minimum Standards For Defined Contribution Schemes and PRSAs:
Employer contributions must amount to not less than 1.5% of the employee’s gross pay or €1,200 in any year, whichever is less.
In addition the aggregate contributions of the employer and the employee cannot be less than 3.5% of the employee’s gross pay or €2,800 in any year whichever is less.
It is important to note the reference to “gross” as opposed to base pay. This is significant as traditionally many pension contributions have been calculated with reference to an employee’s base salary. It is important to be aware that “gross” pay reflects more than just an employee’s base salary. It can include things like commission, bonus etc.
Minimum Standards For Defined Benefits Schemes:
Where a scheme is a defined benefit scheme continuing service in that employment entitles the employee to accrue a long service benefit.
Takeaway for Employers:
Employers who are treating their employee’s employments as exempt from autoenrollment to MyFutureFund on the basis of contributions being made to an occupational pension scheme or PRSA should (if they have not already done so) review the contribution levels to ensure they meet the new minimum standards.
In many cases the contributions may satisfy the standards, however, where there is a shortfall, employers need to be careful about how that shortfall is addressed. Some employers are choosing to make up the short fall through an increased employer contribution in circumstances where seeking to compel an increased employee contribution from existing employees likely presents additional legal issues/challenges.
Employers may also like to review the “FAQ for Employers/Agents” that is available on the MyFutureFund Website (link below).
Links:
https://myfuturefund.ie/employer-faq
https://www.irishstatutebook.ie/eli/2025/si/668/made/en/print?q=enrolment&years=2025
Author –Laura Killelea
23 January 2025
Anne O’Connell Solicitors
19-22 Lower Baggot Street
Dublin 2.
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