To coincide with the launch of Ireland’s auto-enrolment retirement savings scheme, MyFutureFund (MFF), the Automatic Enrolment Retirement Savings System Regulations (Amendment) (Section 52) Regulations 2025 (opens a new window) were formally signed by the Minister for Social Protection on 22 December 2025, and took effect on 1 January 2026.
Introduced despite significant industry opposition, the regulations establish minimum contribution levels that existing workplace pension schemes must meet if they are to be exempt from MFF. The minimum standards will have significant implications for employers’ schemes with contribution structures that are less than the minimum.
What are the minimum contribution standards?
To be exempt from MFF, existing workplace pension arrangements (occupational scheme or PRSA) must meet the following minimum contribution levels:
Total contribution: The lesser of 3.5% of an employee’s gross annual salary, or €2,800 per annum.
Employer contribution: The lesser of 1.5% of an employee’s gross annual salary, or €1,200 per annum.
The exemption standards are designed to ensure that pension schemes outside MFF continue to serve their purpose in allowing participants to accumulate sufficient retirement savings.
The National Automatic Enrolment Retirement Savings Authority (NAERSA) will focus on ensuring schemes comply with these standards, rather than imposing penalties. NAERSA will assess contribution levels over a three-month period and, where the contribution amount falls below the specified 3.5%, the employer will be contacted with a view to assisting them to become compliant.
Implications for employers
The introduction of the minimum standards may now mean that employers are contributing to an existing workplace pension scheme below the threshold for exemption from MFF. Unless employers take action to rectify these shortfalls, the relevant employees will be enrolled into MFF.
There are a few steps that employers should take now:
Determine if you have contribution tiers that are below the specified minimum and the number of employees potentially impacted. If contributions are above the specified minimum, no action is required.
For any cohorts where contributions are less than the specified minimum, consider whether to uplift the contributions in the existing scheme to meet the minimum, or to default these employees into MFF. For schemes which had a non-contributory tier, and where the existing scheme will continue to be used for the specified minimum contributions, employee consent will be required to ensure employees contributions can be deducted from their take home pay.
If needed, amend the contribution structure and pension vehicle for new hires to reflect the new specified minimum contributions.
Revisit your communications to employees, including any HR pension policies and member guides.
Consider the implications of any decisions made for payroll and employment contracts. For example, changes may be required to payroll software, and contracts for existing and new hires may need updating to reflect the changes.
Employers have already made huge efforts to encourage pension participation in 2025. Unfortunately, owing to the unexpected introduction of the minimum standards, many are now faced with having to revisit their schemes.
To discuss the impact of these regulations for your pension scheme, or explore any adjustments needed to your existing arrangements, speak to your Lockton consultant, or reach out to our People Solutions (opens a new window) team.
