Auto-Enrolment into My Future Fund to begin on 1 January 2026

The State’s automatic retirement savings system called “My Future Fund” will now begin on 1 January 2026 instead of the planned commencement date of 30 September 2025.

This aligns the start date with the tax year and provides an additional three months for payroll providers and employers to prepare. As there is no “one size fits all” approach to compliance, preparations for implementation should remain high on the priority list in the months ahead.  

In our briefing we outline the key features of auto-enrolment and the Automatic Enrolment Retirement Savings System Act 2024 (the AE Act)

Who will be automatically enrolled and who will not?

All employees between the age of 23 and 60, who earn at least €20,000 across all employments and who are not in exempt employment, will be automatically enrolled in My Future Fund. National Automatic Enrolment Retirement Savings Authority (NAERSA) will assess income reported through payroll and provide a notification to employers if an employee is to be enrolled in My Future Fund.

Employees aged between 18 and the State pension age (currently 66) who do not meet the criteria can opt in to the scheme provided they are not in exempt employment.

An employee will be in exempt employment if they and/or their employer contribute to a “qualifying pension arrangement”. These arrangements include occupational pension schemes and personal retirement savings accounts (or PRSAs). Minimum standards will be published by NAERSA by the beginning of year seven which will specify minimum contributions that must be paid to a qualifying pension arrangement at that time for the employment to continue to be exempt employment.

Who will be required to pay contributions and at what level?

Employers, employees and the State will be required to make contributions based on a percentage of an employee’s total remuneration (capped at €80,000 per annum) into My Future Fund. The contributions will increase on a phased basis as follows:

What are the consequences of failure to comply with the legislation?

All employers with at least one employee who is subject to income tax in Ireland will need to comply with the legislation. It is important to note that a breach of the legislation is a criminal offence with sanctions ranging from fines of €5,000 to €50,000 and potential imprisonment, depending on the offence committed.

Employers are also prohibited from hindering, penalising or threatening penalisation against an employee for participating or proposing to participate in My Future Fund. Penalisation is widely defined under the legislation and includes, for example:

• suspension, lay-off or dismissal
• demotion, loss of opportunity for promotion nor withholding of promotion
• negative performance assessments

Claims in respect of penalisation could result in a direction from the WRC (or the Labour Court on appeal) to an employer to:

• facilitate the employee’s participation in My Future Fund
• pay any contributions due for that employee from the date they should have been enrolled
• rectify any contraventions of the legislation
• award compensation in favour of the employee (up to four weeks’ remuneration)

What should employers be doing right now?

1. Examine carefully who from within your workforce will be automatically enrolled and who will not.
2. Make any necessary changes to existing pension arrangements and employment contracts to take account of the AE Act.
3. Take action sooner rather the later. Every employer in Ireland must be compliant by 1 January 2026 and if you need support from your current pension scheme administrator in connection with your preparations for the commencement of auto-enrolment, you would be well advised to reach out now, rather than waiting until later in the year.

How we can help

Our pensions and employment law specialists are currently advising employers on the AE Act and what steps need to be taken to prepare for its commencement.

If you would like to find out more about how we can help you prepare for the commencement of auto-enrolment, please contact Chris Comerford, pensions partner, Michael Doyle, employment partner or your usual contact on the Employment or Pensions teams. 

Date published: 8 July 2025