Pandemic or no pandemic, employer obligations remain. With the auto-enrolment (AE) compliance cycle
still fairly new, what should you be doing now?
Despite Covid-19, AE duties apply as normal, whether your staff are working, whether you’ve furloughed
them, or whether you have staff on placement with government funding as part of the Kickstart scheme.
Both you and your staff should continue to make pension contributions. Staff do have the option to
reduce the level of contribution in some circumstances: they can also decide to opt out or cease active
membership of the scheme, if they decide that is the best course of action for them. But it is critical
that as employer, you don’t encourage or induce them to do so: this would breach the legal safeguards
provided for workers under the regime.
If you’re using the furlough or Kickstart scheme, you should run your normal payroll process. Both the
contributions you pay, and your staff pension contributions due under your pension scheme are
calculated on the total pay. That’s regardless of how much government support you are claiming.
If you are a new employer, the pandemic doesn’t make any difference to procedure. You should still
assess staff and put them in a pension if they are eligible. But you may be able to formally postpone
the procedure for up to three months, and we can advise you more fully here. It’s only a delay,
however: it doesn’t cancel your obligations. And it comes with its own admin requirements, so it isn’t
Regular AE housekeeping
The AE regime has its own cycle of responsibilities. This involves regular re-enrolment and
re-declaration duties every three years. In outline, certain staff who have left your pension scheme
must be put back in it. And you then have to submit a re-declaration of compliance to the Pensions
Regulator (TPR), setting out how you have met your duties.
Many smaller employers will be coming up to their first re-enrolment. TPR is likely to write to you
with information about this, recommending that you assess your staff for re-enrolment on the third
anniversary of your staging date or duties start date. Although there isn’t the option to use
postponement for re-enrolment, TPR is providing some flexibility on dates if you are struggling to get
re-enrolment carried out on your third anniversary because of Covid-19.
Here to help
Getting the figures right for pension contributions and the furlough scheme can be extremely complex.
If you would like us to review this for you, please don’t hesitate to get in touch.