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First AE pensions notifications due in December

Lawyers at William Fry have urged employers to take steps to prepare themselves for the start of the new auto-enrolment (AE) pension system on 1 January. 

This follows a recent update from the Department of Social Protection on the timeline for the launch of the system. 

In a note on the firm’s website, the William Fry lawyers say that the department has confirmed its plan to issue the first AE payroll notifications (AEPN) in early December 2025.

‘Critical milestone’ 

The authority responsible for the AE system, NAERSA, will use payroll data from Revenue to determine which employees are in scope, looking back at data over 13 weeks covering September, October, and November. 

The firm describes this as “a critical milestone” ahead of the ‘go-live’ date of 1 January, when contributions to My Future Fund will start. 

Employers should then expect the first AEPNs in early December. 

Cost structure 

An employer portal for the AE system is expected to be launched in early December, after which employers will be asked to register to provide their company details and payment details for future contributions. 

The department also intends to submit a comprehensive memo covering all aspects of the My Future Fund cost structure to the Government in the coming months. This will be made public before 1 January. 

The William Fry lawyers say that proactive preparation from employers is “essential” to ensure compliance with the new requirements. 

They urge employers to: 

• Review payroll data to ensure that all employee records are accurate and current for the 13-week lookback period,
• Decide on their planned approach (encouraging enrolment into their current pension arrangement or operating a dual-scheme approach, with some employees in the AE system and others in the company pension arrangement),
• Engage with advisers to implement their preferred approach,
• Engage with payroll providers to confirm that systems are ready to support AE instructions and contribution processing, and
• Prepare for registration on the employer portal.