The Irish Association of Pension Funds (IAPF) has warned that planned changes to occupational pension regulations may create “unintended consequences” for some employers, following confirmation from the Department of Social Protection (DSP) that the new rules will include a minimum total contribution rate of 3.5 per cent.

The IAPF published the information on its website after it requested an urgent meeting with the DSP, where officials confirmed that employers will be required to pay at least 1.5 per cent of this amount, with the remaining 2 per cent paid either by employers or employees.

The regulations are expected to be signed in the next two weeks and will take effect from 1 January 2026.

The IAPF said most employers already meet or exceed these thresholds, but noted that the new standard could still pose difficulties for certain scheme structures.

In particular, the association raised concerns about how the rules will apply to non-contributory schemes and to arrangements where probationary staff are enrolled at a lower contribution rate for a temporary period before moving to full scheme levels.

In the meeting with the association, the DSP clarified that non-contributory schemes will remain compliant provided the employer contribution reaches the new 3.5 per cent minimum.

However, the IAPF noted that the DSP is concerned about employees being enrolled in any scheme without explicit consent, suggesting this could give rise to data-protection issues unless the enrolment requirement is clearly set out in the employment contract.

The DSP further stressed that it is “strongly opposed” to any differentiation between permanent and probationary employees, insisting that all workers must receive at least the MyFutureFund contribution rate from the outset.

It confirmed that the National Automatic Enrolment Retirement Savings Authority (NAERSA) will be responsible for monitoring adherence once the rules are in force, and employers operating complex non-contributory defined benefit schemes may apply to NAERSA for exemptions where appropriate.

When asked by the IAPF why the measures were not introduced earlier, the DSP said it had been assured that employers would ensure workers were not disadvantaged relative to the MyFutureFund standard.

The DSP announced its intention to introduce minimum standards for occupational pension schemes last week, after stating in October that it had been made aware of some employers incorrectly informing staff they are obliged to join an employer-sponsored pension scheme before the end of 2026.

In a LinkedIn post, IAPF CEO, Joyce Brennan, stated: “We remain deeply concerned about the potential unhelpful consequences of rushed regulations. Our Council and Pensions Committee will meet next week to agree on further representations we will make on behalf of our members.”

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