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18 June 2009

Response to DWP's Automatic Enrolment Consultation

Please click here to download our response (PDF, 38KB)
The downloadable letter contains our response to the Automatic Enrolment Consultation and draft regulations issued by the DWP on 12 March 2009.

We see little reason for forcing new recruits into active membership of a scheme, even if it is the Personal Accounts Scheme, only for them to opt out a few days later.  It will place an unnecessary burden on employers to require them to go through the hoop of automatic enrolment (and possibly deducting contributions only for them to be refunded a few weeks down the line) before the recruit has had the chance to opt out.

The regulations contain prescriptive time limits.  Whilst these may be achievable for larger employers with an adequately resourced and experienced payroll department, they would be unrealistic for small employers who may rely on a single employee to attend to payroll matters on a part-time basis or outsource payroll to a third party.  We suggest such employers should be afforded greater flexibility.  This could be achieved by requiring actions to be completed within a reasonable period, supported by guidance from The Pensions Regulator which could take account of employers’ resources.

For further information:

Gary Tansley
Tel: 01737 841 732
Email: enquiries@hamishwilson.com

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