The National Automatic Enrolment Retirement Savings Authority (NAERSA) has begun contacting employers whose existing pension schemes do not meet the minimum standards required for an exemption from the new MyFutureFund (MFF) auto-enrolment system.

If your business already operates a workplace pension or PRSA, you may have assumed you were covered. That assumption now needs to be tested against the new rules.

How the Rules Have Changed

When auto-enrolment first came into effect on 1 January 2026, an exemption was available in relatively straightforward terms. If either an employer or employee was making any pension contribution through payroll to a qualifying scheme, that employment was treated as exempt. There was no floor on how much was being contributed.

That has changed. A Minimum Standard test is now in place, and NAERSA is actively enforcing it.

What the Minimum Standards Require

To retain an exemption from auto-enrolling staff into MyFutureFund, your existing workplace pension or PRSA must meet both of the following thresholds (effective from 1 January 2026):

• Employer Contribution: At least 1.5% of gross pay, or €1,200 per year — whichever is the lower figure.
• Total Combined Contribution (Employer + Employee): At least 3.5% of gross pay, or €2,800 per year — whichever is the lower figure.

Schemes that fall below either threshold are no longer treated as qualifying for exemption.

How NAERSA Has Approached Enforcement

While these standards became law on 1 January 2026, NAERSA did not begin automated eligibility testing immediately. Instead, their approach involved reviewing payroll data from the first 13 weeks of 2026 to identify employers whose contributions fell below the required levels, before following up directly with those businesses.

That review period has now concluded. NAERSA is in the process of contacting non-compliant firms to discuss what steps they intend to take to bring their pension arrangements up to standard.

The Risk of Dual Contributions

For employers who do not act, the consequences are significant. If NAERSA issues an Auto Enrolment Pension Notification (AEPN), your business and your employees could end up contributing to both your existing pension scheme and MyFutureFund at the same time. That is a material additional cost that most businesses will want to avoid.

NAERSA has indicated it will allow a window for employers to address contribution shortfalls before issuing an AEPN. That window needs to be used.

What Your Options Are

If your current scheme does not meet the required standards, there are broadly three routes available.

• Increase both employer and employee contributions to bring the combined total up to the statutory minimum. This is the most straightforward approach where both parties have room to move.
• Absorb the shortfall as an employer. Some businesses may choose to increase the employer contribution alone to cover the gap, without asking employees to contribute more. This provides a clean solution but comes at a direct cost to the business.
• Evaluate a move to MyFutureFund. For some employers, particularly where the existing scheme is marginal or the administrative burden is high, it may make more financial sense in the long run to close or wind down the existing arrangement and enrol employees in the state scheme instead.

Each of these options has different cost, contractual and employee communication implications, so it is worth reviewing them carefully before deciding.

What to Do Now

If you have received contact from NAERSA, or if you are uncertain whether your current scheme meets the minimum standards, the time to act is now. Waiting until an AEPN is issued significantly reduces your options and increases your costs.

To arrange a consultation regarding these pension standards and how they affect your workforce, please contact Philomena Lawlor.