For many large employers their staging date is a distant memory and auto-enrolment has become business as usual. Nevertheless, there is still more to do as the third anniversary marks the first re-enrolment cycle.The good news is employers do not have to repeat everything they did on their staging date. Re-enrolment should be less onerous because it only applies to those who opted out in the first round. However, as always, it is important to get the details right.
First, employers must choose a re-enrolment date. This can be any day three months either side of their staging date’s third anniversary. Employers should double-check their staging date: it should not be confused with a deferral date if they used postponement.
Also, if there are multiple employers in the same corporate group they may have different staging dates. They also need to be strategic. The re-enrolment date cannot be postponed for individual workers and employers should consider aligning it with their pay reference dates.
Employers need to consider key business dates because additional worker assessments, communications and contribution deductions will be required, so it would be sensible to avoid other busy periods.All employers should revisit their service contracts with pension providers to ensure re-enrolment is within scope. Early engagement is essential, particularly for large employers, which may be the test case for their provider’s systems and software.
For many employers, the law will have changed since their staging date. When implementing re-enrolment, employers may also wish to incorporate some of the helpful easements that were introduced in April 2015. This includes an employer discretion not to enrol those who have opted out in the previous 12 months, are due to leave their job or have pension tax protection.
Looking ahead, re-enrolment should be a case of repeating the same process every three years, so it is worth spending time getting it right first time.
Jen Ackerman is an associate at Hogan Lovells
