Key issues for employers post auto-enrolment staging

There are myriad auto-enrolment duties for employers to consider beyond their staging date.


  • Post auto-enrolment staging date, employers must keep on top of a number of tasks to remain compliant.
  • Having robust record-keeping and data processes in place is key.
  • Employers must ensure they send relevant communications to their workforce at the required times.

Preparing for auto-enrolment may feel like an uphill struggle for many employers. So, once they have successfully enrolled all eligible staff, they may be tempted to sit back and give themselves a pat on the back.

But this is only the beginning. Post-staging date, there are a number of issues employers must take into account to ensure ongoing compliance. Paul Leandro, an associate at Barnett Waddingham, says: “Auto-enrolment is not a pensions matter, it’s a process matter. So, post-staging date, [organisations] need to have robust processes in place.”

Specifically, employers must have processes in place to continually assess the workforce to identify individuals who become eligible, or ineligible, for auto-enrolment. These processes must be updated when appropriate, for example in line with rising contribution levels.

Clare Abrahams, head of auto-enrolment at Lorica, says: “Every single month, [employers] have to have a full employee data set that goes through the system. They have to set it up so the data flows through the system easily and they need to send out communications that are due for new hires, or when people hit eligibility later. They have got to be able to give salary details that allow for band earnings, qualifying earnings and pensionable salary.”

These processes will enable employers to identify staff who become eligible jobholders each month, whether on a permanent basis by reaching the age of 22, or if a pay rise lifts them above the qualifying earnings threshold, or temporarily due to fluctuating income resulting from, say, bonus or commission payments.

Fluctuating income

Ian Hall, senior consultant at Broadstone Corporate Benefits, says: “Not everybody has a basic monthly salary of £2,000; it can fluctuate. At the staging date or first assessment date, an employee might not fall into the category of an eligible jobholder, but the next month they might do because of overtime, commission or bonuses. Then they might fall out again, so how do [employers] manage that process?”

In many cases, employers may only have a small window each month to compile this data. Dale Critchley, technical reform manager at Friends Life, says: “One of the biggest things to ask is: how does the assessment process fit into payroll? [Employers] need to ensure external assessment processes, where used, can supply the data required and that auto-enrolment assessments don’t hold up people being paid.”

So, robust processes are vital, particularly for assessing new hires, which should ideally be in the first payroll after they join. “People who start at the end of the month may be missed off,” says Critchley. “But they need to be assessed in the first month after they are hired, not the second. Most organisations will use postponement to get the data up to date.”

Postponement also requires employers to keep clear records which can be shown to The Pensions Regulator at any time on request.

Record of opt-outs

They must also keep a record of opt-outs to manage any refunds due, and to automatically re-enrol all eligible staff every three years. Barnett Waddingham’s Leandro says: “Hopefully, organisations will have software that keeps a record of [opt-outs and re-enrolments] automatically. If employers haven’t used those systems, they will have to keep a record themselves, which will be very difficult. There is a danger of people being missed.

“Organisations also need to be careful in terms of where responsibility lies for data capture. For example, if they are using a pension provider’s system to keep records of opt-outs, opt-ins and re-enrolments, where does the responsibility lie if a mistake is made? They need to be clear about this when signing up to these systems or to a new pension plan.”

Jamie Jenkins, head of workplace strategy at Standard Life, adds: “If you miss a tranche of people who opted out but would have stayed in [the pension scheme] next time round, but you forget to re-enrol them, then somebody has to be liable for that.”

Ongoing pensions governance post-auto-enrolment is therefore vital. Jenkins says employers should consider several key questions to ensure their arrangements remain fit for purpose. “The big thing for me is putting in place an affordable and manageable process that allows an employer to say at least once a year for any scheme: ‘How are things working? How many people have stayed in? Are people paying sufficient contributions based on their affordability? Are they in the right default fund? How many people chose to opt out of the default fund and use something different?’”

Review providers

Employers should also regularly review their pension scheme providers and advisers, as well as middleware providers to ensure they remain the most appropriate choice.

Post auto-enrolment, communication with staff is another ongoing task for employers. In the first calendar month after enrolment, they are required to issue communications explaining that employees can opt out if they want. However, these must be written in a way that cannot be considered to be inducing staff to opt out. Employers face a particular challenge around employees with enhanced protection of existing pension benefits, who could be liable for a tax charge if any additional money is paid into their fund.

With more employees likely to be pension scheme members, employers may focus more on communications and supporting staff in saving for their retirement. Leandro says: “There is now more onus on organisations to make sure people have enough in their pension pot, that enough contributions are paid in and that people actively review their arrangements throughout the lifetime of the pension policy. These things will have to be explained to staff in a way that gets them engaged with pensions.”

So, auto-enrolment looks set to keep employers busy for years to come. As Robin Hames, head of marketing at Capita Employee Benefits, says: “The staging date is the start of the work, not the end of it. You can’t breathe a sigh of relief when you hit your staging date.”

Case study: KFC has fast service on auto-enrolment data


KFC installed processes to handle ongoing auto-enrolment compliance issues before reaching its staging date on 1 April 2013.

The fast food chain’s workforce includes a large number of weekly-paid and young employees under the age of 25 as well as its salaried population. It therefore has a number of staff who are on the cusp of meeting the qualifying criteria for auto-enrolment, and could find that they do so because of fluctuating pay levels.

To ensure the process runs as smoothly as possible, KFC assesses who is likely to become eligible for auto-enrolment when each weekly payroll takes place. It then informs the managers of all employees affected to enable them to help communicate this to these individuals.

Craig Truter, total reward manager at KFC, says: “By doing an assessment at payroll time, we can give a heads-up to the management of restaurants so they can talk to any individuals affected. By keeping it relevant and by highlighting who will be impacted on a week-by-week basis, we can be more targeted.”

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Assessments are carried out under an arrangement between KFC’s internal payroll department, using software hosted by Capita, and pension providers Scottish Widows and The People’s Pension. Advice and project management are provided by Lorica Employee Benefits.

KFC has built an online learning module on auto-enrolment into each employee’s training account, which they can access when appropriate. Truter says: “If they are being auto-enrolled coming up to a busy season like Christmas when they are likely to do lots of hours and get bonuses, they can go into [the module] at that point and get all the relevant information.”

Source: Dale Critchley, Friends Life