All bureau payroll providers will, by now, be very familiar with how to deal with clients who have had a staging date allocated to them by the Pensions Regulator.
However, this staging process is nearing an end and new employers, who take on staff after 1st October 2017, will have immediate automatic enrolment duties. They will no longer be allocated a staging date by the regulator.
These employers will still be able to postpone for up to three months to allow them the time to choose and set up a pension scheme.
Heretofore, it was essential that any postponement communication was sent to postponed employees within 6 weeks of the staging date. Under the new regime, the staging date will now be referred to as the duties start date. This duties start date will be the date that the first employee started. Any postponement communication will now need to be sent within 6 weeks of the duties start date.
If the first employee is a director, then the company will have no AE duties until such time as a second employee commences. In this case it is the start date of this second employee that becomes the duties start date.
ABC Limited commences trading on 1st December 2017 and has one employee, being a director. On 1st March 2018, ABC Limited takes on a new employee.
The duties start date for ABC Limited is 1st March 2018 and ABC Limited has no AE duties until this date. If ABC Limited decides to postpone, a communication will need to issue on or before 12th April 2018. Assuming that ABC Limited is paying monthly, on 31st March, when it is processing its payroll, it may choose to postpone (for up to 3 months) and issue the communication at the time of doing the March payroll.
If the postponement is for 3 months then, when processing the payroll at 30th June 2018, being completion of the postponement period, all employees must be assessed and enrolled if necessary. The same ongoing duties still apply and, each pay period, all non-enrolled staff should be assessed for age and earnings to see if they need to be enrolled or given the option to enrol.
There are transitional rules for employers taking on their first employer between 2nd April 2017 and 30th September 2017.
BrightPay payroll software will guide the user through the process for new employers.