OVERVIEW AND KEY DATES
With MyFutureFund now live, employers can expect automatic enrolment to become a practical payroll issue rather than a future policy change. The scheme commenced on 1 January 2026 and applies to eligible employees who are not already covered by a qualifying pension arrangement through payroll. It is administered by the National Automatic Enrolment Retirement Savings Authority (NAERSA), which will carry out eligibility checks, issue payroll notifications and oversee the collection of employee, employer and State contributions.
UPDATED STATUTORY INSTRUMENT
S.I. No. 668/2025 (Automatic Enrolment Retirement Savings System Regulations (Amendment) (Section 52) Regulations 2025), made on 22 December 2025 and effective from 1 January 2026, introduced minimum standards for when an occupational pension scheme or PRSA can be relied on to claim an exemption from enrolment into MyFutureFund.
The Regulations insert Schedule 1A into the Principal Regulations and provide that these standards apply for the purposes of section 51 of the Automatic Enrolment Retirement Savings System Act 2024 (exempt employments). They are particularly relevant for employers relying on payroll PRSAs or defined contribution schemes to keep roles outside MyFutureFund.
In summary, for defined contribution occupational schemes and PRSAs to be deemed exempt under the 2024 Act, the minimum standards now require
- an employer contribution of at least 1.5% of gross pay or €1,200 per year (whichever is lower); and
- combined employer and employee contributions of at least 3.5% of gross pay or €2,800 per year (whichever is lower).
GUIDANCE: AT A GLANCE
- Who is auto-enrolled: Employees aged 23–60 earning €20,000+ per year across all employments, who are not in exempt employment.
- Rates (2026–2028): Employee 1.5% + Employer 1.5% + State top-up 0.5% (on gross pay up to €80,000).
- Eligibility assessment: NAERSA uses Revenue payroll data; a lookback period of up to 13 weeks may apply for new starters or irregular earnings (no backdated contributions for that period).
- When contributions are due: Contributions must be paid to NAERSA at the same time as the employee is paid (per pay date).
- What is “exempt employment”: A payroll-based qualifying occupational scheme/PRSA/RAC/PEPP that meets the exemption standards (see below for further detail).
- December 2025 exemption standards: Defined contribution schemes/PRSAs through payroll must average at least 3.5% total contributions, including at least 1.5% employer, subject to caps.
- Opt-out / suspension: Opt-out window is months 7–8 after enrolment (and after each rate change); suspension is for 1–2 years after the mandatory 6 months.
- Key compliance risks: Late/withheld contributions and any conduct that hinders participation can lead to enforcement action, fines and potential prosecution.
EMPLOYEE ELIGIBILITY AND NAERSA ASSESSMENT
An employee will be automatically enrolled if they:
- are aged between 23 and 60;
- earn €20,000 or more per annum across all employments; and
- are not in exempt employment (i.e. no qualifying pension contribution through payroll for that employment).
Employees under 23 or over 60, or earning under €20,000, may choose to opt in. NAERSA determines eligibility using Revenue payroll data. Where a clear earnings record exists, enrolment is immediate; otherwise NAERSA can use a lookback period of up to 13 weeks and contributions are not backdated for that period.
Eligibility is assessed across all employments for the €20,000 threshold. If an employee has more than one job, they may be auto-enrolled for any employment where there is no exempt pension coverage through payroll.
EMPLOYER OBLIGATIONS (PRACTICAL)
Employers should assume they have obligations in three areas: portal setup, payroll processing, and employee communications.
Portal setup
- Register on the MyFutureFund employer portal and set up a payment method (NAERSA recommends variable direct debit).
- Employer/agent access is via ROS credentials/certificates (no separate portal login).
Payroll processing
- Retrieve and apply the Auto-Enrolment Payroll Notification (AEPN) for each pay run (the AEPN instructs enrolments, opt-outs, suspensions and applicable rates).
- Deduct the employee contribution and calculate the matching employer contribution on gross pay (up to €80,000 per year).
- Pay employee and employer contributions to NAERSA at the same time as the employee is paid.
Employee communications
- Inform employees when they are first enrolled and confirm the enrolment date. NAERSA provides compliant “welcome letters” in the employer portal mailbox.
- Ensure managers do not encourage or pressure employees to opt out or suspend contributions.
CONTRIBUTIONS AND PAYROLL MECHANICS
Rates and earnings cap
| Period | Employee | Employer | State top-up |
| Years 1–3 (2026–2028) | 1.5% | 1.5% | 0.5% |
| Years 4–6 (2029–2031) | 3.0% | 3.0% | 1.0% |
| Years 7–9 (2032–2034) | 4.5% | 4.5% | 1.5% |
| Year 10+ (2035 onwards) | 6.0% | 6.0% | 2.0% |
Contributions are calculated on gross earnings (including allowances, overtime and commission where included in gross pay). No contributions are levied on gross pay above €80,000 in a calendar year. Where the €80,000 threshold is exceeded within a pay period, contributions may be taken on the full pay for that period and the AEPN will then update for the remainder of the year.
Timing of payment
Contributions must be paid to NAERSA at the same time as the employee is paid. For monthly payrolls, this means the contribution becomes due on each monthly pay date.
Unpaid leave and inactivity
If an employee is on unpaid leave (for example, unpaid sick leave or unpaid maternity leave), contributions are not deducted for the period of unpaid leave. Where an employee opts out or suspends contributions, matching employer contributions cease for that period.
Tax treatment (high level)
Government guidance indicates that employee MyFutureFund contributions do not receive standard pension income tax relief; instead the State provides a top-up (€1 for every €3 contributed by the employee). Employer contributions are intended to be tax-deductible for the employer and not treated as a benefit-in-kind for the employee. Tax treatment at drawdown/retirement is expected to follow broadly similar principles to other supplementary pension arrangements.
How NAERSA will assess exemption and compliance
NAERSA has indicated it will assess contribution levels over a three-month period (the same basis as the earnings assessment for MyFutureFund eligibility). Where contributions fall below the standards, NAERSA expects to contact employers to assist them to become compliant. However, continued non-compliance with no evidence of appropriate steps may lead to enforcement of NAERSA’s compliance powers under the Act.
Practical examples (defined contribution/PRSA)
- Employee contributes 3.5% via payroll; employer contributes 0%. Not exempt (employer minimum of 1.5% not met).
- Employer contributes 3.5% via payroll; employee contributes 0%. Exempt (total >= 3.5% and employer >= 1.5%).
- Employee 2.0% + employer 1.5% via payroll. Exempt (total 3.5% and employer minimum met).
- Employee 1.0% + employer 0.5% via payroll. Not exempt (total < 3.5% and employer < 1.5%).
Important: contributions made outside payroll (for example, an employee paying directly to a PRSA by direct debit) are not visible to NAERSA through Revenue payroll data and will not, of themselves, make an employment exempt.
The Auto-Enrolment Act does not remove existing obligations to provide access to a PRSA where required under pensions legislation; employers should continue to comply with those obligations alongside MyFutureFund.
Opt-out, suspension and re-enrolment (employee choices)
MyFutureFund is not fully mandatory. Employees must stay enrolled for a minimum of six months, after which they may opt out or suspend contributions in defined windows.
Opt-out
- Employees can opt out six months after enrolment, during months seven and eight.
- Employees can also opt out six months after each contribution rate change (during months seven and eight after the change).
- If an employee opts out, their contributions are refunded; employer and State contributions remain invested for their benefit.
- Employees who opt out and remain eligible will be automatically re-enrolled after two years.
Suspension
- Employees can suspend contributions at any time outside the initial six-month mandatory participation period.
- Suspension is for a period of 1–2 years; employees cannot resume contributions before at least one year has elapsed.
Re-Enrolled
After a maximum of two years, eligible employees are automatically re-enrolled.
Operationally, opt-outs and suspensions are actioned through NAERSA and are reflected back to employers via AEPN updates.
Penalties, Enforcement and HR risk points
Employers should treat MyFutureFund as a statutory payroll obligation. Failure to apply AEPN instructions, deduct and remit contributions, or withholding contributions can trigger enforcement action. Government guidance also highlights that it is an offence to hinder or attempt to hinder employee participation (including pressuring staff to opt out or suspend).
Common HR pitfalls to avoid:
- Offering “cash in lieu of pension” arrangements without ensuring the employee is in exempt employment (these employees may still be auto-enrolled).
- Assuming a non-payroll PRSA (paid directly by the employee) will prevent auto-enrolment.
- Relying on a token PRSA contribution that does not meet the new exemption standards (3.5% total / 1.5% employer).
- Failing to issue enrolment notifications to employees or to keep evidence of communications.
Practical implementation checklist (first 30 days)
- Confirm employer portal registration and payment method (ideally variable direct debit).
- Confirm payroll software is updated to retrieve and apply AEPNs and to submit contribution information to NAERSA.
- Map pay elements that fall into ‘gross pay’ (overtime, commission, allowances) so the contribution base is accurate.
- Audit existing occupational scheme/PRSA contribution levels for roles you wish to keep exempt; adjust contribution structures to meet the December 2025 standards where needed.
- Prepare a short employee communication explaining (i) the scheme, (ii) contribution rates and pay cap, (iii) opt-out/suspension options, and (iv) where to find NAERSA portal support.
- Train HR and line managers: no pressure on employees to opt out; refer queries to HR/payroll/NAERSA as appropriate.
- Keep records of AEPNs applied, payments made, and enrolment notifications issued.
FAQs
Q: Do we need to amend employment contracts to implement MyFutureFund?
A: Generally, no. MyFutureFund operates by law. Employers should, however, ensure policies/communications are updated and that payroll processes are compliant.
Q: If we already offer a PRSA, are we automatically exempt?
A: Not necessarily. Exemption is per employment and depends on actual contributions through payroll to a qualifying arrangement meeting the exemption standards.
Q: Does an employee’s personal PRSA paid by direct debit make the employment exempt?
A: No. NAERSA relies on Revenue payroll data. Contributions outside payroll are not visible for exemption purposes.
Q: What are the new exemption standards for defined contribution schemes/PRSAs?
A: Total contributions must average at least 3.5% of gross pay, including at least 1.5% employer contribution, subject to the €80,000-related caps.
Q: If an employee contributes 3.5% to a payroll PRSA but the employer contributes 0%, is the employment exempt?
A: No, on the current standards (employer minimum of 1.5% is required for defined contribution/PRSA exemption).
Q: If an employer contributes 3.5% to a payroll PRSA and the employee contributes 0%, is the employment exempt?
A: Yes, provided it is a qualifying PRSA and the contributions are properly reported through payroll.
Q: When do we pay contributions if payroll is monthly?
A: Contributions are due at the same time as the employee is paid. For monthly pay, that means each monthly pay date.
Q: Does the €20,000 eligibility threshold look at each job separately?
A: No. Eligibility for the €20,000 threshold is assessed across all employments, but enrolment occurs only for employments without exempt pension coverage.
Q: Do we still have to provide access to a PRSA under existing pensions rules?
A: Yes. The Auto-Enrolment Act does not remove existing PRSA access obligations.
Q: Can employees opt out or suspend?
A: Yes. They must stay in the scheme for 6 months, then can opt out in months 7 and 8 (refund of employee contributions). Alternatively, they can suspend for 1–2 years (no refunds).
Q: Are the employee contributions taken from net or gross salary?
A: The contribution are taken from the net income, after deductions.
Q: How do employees access their MyFutureFund accounts?
A: To access the account, employee will need to visit MyFutureFunds portal and log in using their verified myGovID credentials to log in.
