The Irish Association of Pension Funds (IAPF) notes with concern the recent communication from the Department of Social Protection indicating that regulations introducing minimum contribution rates may be implemented “in the near future.”

Our members carry out valuable work to ensure employees have access to high-quality pension schemes, and most employers will not be adversely affected by these changes. However, we are concerned that certain employers and trustees could face unintended consequences, particularly in two areas:

1. Non-contributory schemes, and
2. Probationary employees enrolled at a lower contribution rate for a temporary period before qualifying for full contribution rates

On behalf of our members, we met with the Department to seek clarity on these issues. Below is a summary of the information they provided:

• The Department intends to implement regulations within the next couple of weeks, effective 1 January 2026.
• These regulations will introduce a minimum contribution rate of 3.5% of gross pay, with at least 1.5% paid by the employer. The remaining 2% may be paid by either the employer or the employee.
• Non-contributory schemes will not be impacted provided the employer contribution is at least 3.5% of gross pay.
• The Department expressed concern about employers enrolling members in pension schemes without consent, even for non-contributory schemes, citing potential data protection issues. Their position is that employees should not be enrolled without consent unless this is explicitly stated in their terms of employment.
• The Department is strongly opposed to any practice that differentiates temporary or probationary employees. All employees must receive at least the MyFutureFund contribution rate, regardless of whether higher rates apply after probation.
• NEARSA will monitor compliance with these new regulations.
• The Department acknowledges the complexity of non-contributory defined benefit schemes and advises employers to apply to NEARSA for an exemption where appropriate.
• When asked why these measures were not introduced earlier, the Department stated they had been assured that employers would act to ensure employees were not disadvantaged compared to MyFutureFund standards.

Our Council will meet next week to consider next steps. We remain committed to working constructively with the Department to ensure that these regulations achieve their intended purpose without creating unnecessary challenges for employers or employees.