Compensation & Benefits: Update on proposed auto-enrolment pension reforms

January 3, 2010

“Pragmatic approach” welcomed as “major step forward”

Following the Department for Work and Pensions’ (“DWP”) consultation
exercise in September 2009, key changes have been made to the draft
regulations initially published.  The revised regulations relate to
employers duties set out in the Pensions Act 2008 and were laid before
Parliament on 12 January 2010.  The regulations will introduce a
requirement for all employers to automatically enrol workers and pay
contributions into their workers’ pension schemes.

The amendments have been made in accordance with the DWP’s stated
aim to establish a “minimum level of effective regulation without over
specifying process steps” and are set out below:

Auto-enrolment will begin as planned in October 2012 and will be
fully phased in by October 2017.


New and smaller businesses will welcome the additional time allowed
before they are required to auto-enrol their employees into a pension

However, employers operating defined contribution pension schemes
will be disappointed to note the withdrawal of the self-certification
rules.  The DWP has explained that it is currently seeking a long term
solution in conjunction with the pension industry but, unless a
replacement self-certification mechanism is proposed by the DWP,
employers with such schemes will be subjected to increased costs and
additional administrative burdens as a result of having to undertake a
full reconciliation of their records each year with the statutory
quality standard for these schemes.


The main regulations are set out below.  For details of the other
regulations, please visit:

Pension (Automatic Enrolment) Regulations 2009: Government response to
the consultation

paper on Workplace Pension Reform: Completing the Picture

Occupational and Personal Pension Schemes (Automatic Enrolment)
Regulations 2010

Employers’ Duties (Implementation) Regulations 2010

Employers’ Duties (Registration and Compliance) Regulations 2010

further information or to discuss the issues raised, please contact Guy
Abbiss (
or Colina Greenway (
on +44 (0) 203 051 5711.


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