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Submission to Joint Committee on Social Protection, Community and Rural Development and the Islands – General Scheme of the Auto Enrolment Retirement Savings System Irish Life Group Submission November 2022 1 INTRODUCTION ABOUT IRISH LIFE GROUP Irish Life Group (ILG) includes inter alia Irish Life Assurance, Irish Life Health, its intermediary and advisory businesses as well as its associated companies Irish Life Investment Managers and Setanta Asset Management.
We currently have over 3,000 people working at our campuses in Dublin and Dundalk, and we continue to grow.

Irish Life Assurance plc and Irish Life Health are subsidiaries of Irish Life Group Ltd and is one of Ireland’s leading life and pensions companies with over 1.5 million customers.

For over 80 years, it has helped people in Ireland embrace change and build better futures through its innovative products and dedication to customer care.
Since 2013, Irish Life Group has been a part of Great-West Lifeco Inc., one of the leading financial service providers in Canada.

Great-West Lifeco Inc. cares for more than 33 million clients around the world.

EXECUTIVE SUMMARY Irish Life Group welcomes the opportunity to make a submission to the Joint Committee on Social Protection, Community and Rural Development and the Islands.
Irish Life, as Ireland’s leading pensions provider, welcomes the publication of the General Scheme of the Auto Enrolment Retirement Savings System (hereinafter ‘the AE Bill’) and believes that the introduction of auto enrolment will drive a cultural change within Ireland for generations to come, enabling better pension provision and retirement outcomes for all.
The introduction of Auto Enrolment in Ireland will be a seminal moment for 750,000 people who will be provided with the opportunity to put in place a more financially secure retirement.

Auto Enrolment is the most significant change in pensions policy for decades and has the capacity if implemented correctly to positively change the retirement outcomes for generations to come.

It is a social good that should be implemented quickly, correctly and with the best outcome for all members at its core.
The core principles of a universally available affordable scheme that could be implemented in a reasonable time frame were well thought through in the Pensions Strawman developed over years and published in 2018.

The response to the consultation on the Strawman was very positive and it provided an excellent foundation on which to build.

However, the AE Bill sets out a model which fundamentally differs from that set out and consulted upon in the Pensions Strawman.
The Strawman had as a core principle the need to provide choice to consumers, choice of provider, choice of contributions and choice of investment manager.

However, this key principle has been completely removed from the proposals as set out within the AE Bill with the creation of a State monopoly.

Both European and Irish law prohibits the State discriminating against women, both directly and indirectly.
However, the current proposals will embed the pensions gender gap for generations of women and put women in the auto enrolment scheme at a disadvantage compared to those within occupational pension schemes.

Similarly, a key tenant within the Pension Roadmap 1 was that the introduction of the Auto Enrolment scheme should not de-stabilise existing occupational pension schemes however a number of the proposals set out within the AE heads would seem to specifically contradict this proposal.
The added complexity also contradicts the principle of simplicity in the government’s own Interdepartmental group paper.

The current 1 gov.ie - Automatic Enrolment Strawman Submissions (www.gov.ie) 2 model proposed will add unnecessary cost, uncertainty and complexity compared to the use of existing pensions providers as set out within the Strawman.
Irish Life has carried out international benchmarking of the model proposed by the AE Bill and would note it varies from that taken in the UK, Australia and New Zealand and lessons should be taken from these jurisdictions.

All of these jurisdictions used existing pensions infrastructure to deliver Auto Enrolment rather than create, establish and build a completely new State system.
As the AE Scheme will effectively be the largest defined contribution master trust in the State it members should be afforded all the same protections as set out with the rules, governance and regulation that applies to every other Master Trust.

In the following submission Irish Life will set out its key concerns in relation to the revised CPA model and set out recommendations on how this can be amended for the betterment of customers, the industry and Ireland.
Irish Life is fully supportive of the Auto Enrolment model and its core principles, however, it does not believe that the method of implementation via a State CPA is the best model for either customers or the State.

With a small reversion to the proposal as set out with the initial Pensions Strawman a better outcome can be achieved for all.
Irish Life would like to thank the Committee for providing the opportunity to set forwards its views on the Auto Enrolment scheme and welcomes the legislative scrutiny and debate that will be carried out by the Committee when reviewing this landmark policy.

Irish Life welcomes the open nature of the consultation and the thorough assessment of the Auto Enrolment policy to be carried out by the Committee in order to ensure that the best possible scheme is put in place for the benefit of all.
Submission PART 2 – PARTICIPANTS Head 4 – Criteria for Automatic Enrolment The Pensions Council issued a report to the Minister for Social Protection in March 20222 on the Gender Pensions Gap, within which it set out a number of recommendations in relation to the Auto Enrolment scheme.
It relied on data from an ESRI in 2019 entitled ‘Gender, Pensions and Income in Retirement’ 3 which found that 55% of men and 28% of women were in receipt of occupational and private pensions and that the average total weekly pension income was €280 for women and €433 for men.

This is a similar conclusion that that reached by Irish Life research into the pensions gender gap within its own corporate defined contribution business.
The earning threshold of €20,000 will remove more women than men from inclusion in the AE scheme.

In addition, the Heads of Bill is entirely silent on what will occur when women go on maternity or parental leave.

The Irish Life Pension Parity Report4 has shown the impact that gaps in employment can have on a woman’s pension scheme.

In particular, due to the effect of compounding taking periods out of employment earlier in your career rather than later will great a much bigger gap into the future.
In addition, as recognised with explanatory note for Head 6, women are likely to have more part time and multiple employments that will bring them within the salary limits however it is unlikely that any one employer will have visibility of this multiple employers.
Therefore, rather than the CPA acting as the gate holder it would make more sense that similar to New Zealand, the Revenue Commissioners are the primary point of 2 report-on-gender-pension-gap.pdf (pensionscouncil.ie) 3 https://www.esri.ie/system/files/publications/RS87_1.pdf 4 In Search of Pension Parity: Ireland’s Gender Pension Gap | Irish Life Corporate Business 3 engagement for employers.
The Revenue Commissioners are best placed to assess if employees earnings in aggregate are breaching the salary thresholds and to then instruct that deductions be made.

Not only does the auto enrolment scheme make no reference to what will occur during periods of unpaid leave, more worryingly it provides no mechanism by which women can top up their pensions to remedy any gap that can occur.
The current AE Bill does not allow for either employees or employers to make additional contributions and is therefore embedding a pensions gender gap into the AE scheme.

Not remedying this problem from the beginning of the design means that any woman within the scheme will be placed at a disadvantage as soon as they take any unpaid leave, and even if a remedy is put in place in the future, due to compounding it will be much worse than if it had been fixed from the beginning.
While this lack of flexibility to make additional contributions will predominately affect women who do not have linear 40 year careers, it will also impact any member who either loses their job, goes on long term illness or takes parental leave as they will have no possibility to make additional contributions to the scheme to make up the gap.
In the explanatory note to Head 5, it recognises that the AE target population is: “As this group will change jobs frequently, whether due to career progression, participation in the gig economy or job insecurity, it is important that each change does not represent a pause in contributions.” This is used to justify the ‘pot follows the member’ but actually says nothing about what happens when a gap does occur.
In addition, it should be noted that while ‘pot follows the member’ is stated repeatedly throughout the AE Bill this is not strictly correct, the ‘pot follows the member’ only for so long as the member is with an employer that has AE, if they join an occupational scheme there is no way to combine pots.
This inflexibility of contributions levels for employees and employers, is a fundamental change from the Strawman proposal to the detriment of consumers and is completely different to the rules imposed for occupational pension schemes where under law a scheme is obliged to either allow Additional Voluntary Contributions by a member within the scheme or facilitate an AVC PRSA for the member to make additional contributions.
These rules allow any employee (or employer) flexibility to increase their contribution rates.

For younger women in particular who may envisage periods of unpaid leave into the future due to family commitments the clear advice should be to increase contributions in advance of this occuring to smooth out any potential gap, and if possible to increase contributions once they return from unpaid leave.

However, this may not be economically feasible.


It is also open to employers to increase contributions to smooth out pension gaps, Irish Life increases its employer contributions for a year after a person returns from maternity leave to bridge any pensions gap that may have been created through a period of unpaid leave.

None of this is possible under the current AE Heads of Bill.

Similarly, under occupational pensions scheme there are differing tax relief rates and contribution levels based on age.
This recognises that for persons joining schemes later they may need to make additional contributions to make up for any gaps in cover.

However, there is no flexibility or leeway provided within the AE scheme for older members to make up any gap that might be present.

This could lead to age discrimination as they are prevented through the scheme from increasing their contributions.
4 While a primary purpose of the AE scheme is to increase pensions coverage, this aim needs to be directly linked to pensions adequacy and to encourage saving.

Hence, to devise a scheme that directly prohibits additional contributions would seem to contradict the entire spirit of the AE scheme.
Recommendations on Head 4: • Reduce the salary limit for Auto Enrolment and follow recommendations set out by the Pensions Council in relation to gender proofing the system; • Revert to proposal as set out within the Pensions Strawman and allow flexibility of contribution levels by employees and employers beyond the statutory minimum; • Make the Revenue Commissioners the central point for engagement for employers rather than the CPA.
• Align contribution rules to those within occupational pensions schemes for both AVC’s and age.

• Carry out a regulatory gender and age impact assessment of the current proposals as set out within the Heads of Bill.

Head 9 – Rates of contribution/ incentive Irish Life agrees with the rates of contribution and phasing, however, as stated above it does not agree with the inflexibility of the contribution rates.
It is noted that differing to the Strawman proposals that the onus has now been placed on the employer to calculate contributions.

For smaller and middle sized employers the AE scheme needs to be as simple and administratively efficient as possible.

Hence, as stated above the recommendation would be that the Revenue Commissioners take on the functions of the CPA and made the deductions directly.

All employers have a relationship with the Revenue Commissioners already and this would simplify the process.
It is noted that the State top-up is fundamentally different to the current tax relief system for occupational pension scheme.

The creation of a separate state incentive to that in place will add complexity to the pensions market.

The UK which has a pension system closely resembling our did not create a new State incentives when introducing Auto Enrolment.
In particular, for large employers and FDI’s who are matching contribution rates to AE within occupational schemes there will be pressure to put standard rate tax payers into the AE scheme and those on higher salaries within occupational schemes.

They would also need to closely monitor each employees salary increases and promotions to assess which scheme is best for them.
5 Differing from the Strawman, as the proposal is to create a State Monopoly for AE, employers will need to deal with two differing providers dependent on the salary ranges of staff.

Recommendations on Head 9: • Create equity between the lower paid in both auto enrolment and occupational pension schemes by increasing tax relief on the standard rate to 25%.

• Align the State incentive – increase the tax relief for occupational schemes to a minimum 25% to match the levels within Auto Enrolment.
[insure lower paid not discriminated – equity for lower paid by increasing tax relief for standard rate to 25% • Revert to Strawman Proposal and allow pensions providers also offer Auto Enrolment so employers can deal seamlessly with one provider • Make the Revenue Commissioners the central point for engagement for employers rather than the CPA.

• Align contribution rules to those within occupational pensions schemes in particular for differing contributions on age.
• Provide for a State incentive during periods of maternity leave and allow efficient tax mechanism for partners to make contributions when on unpaid leave.

• Allow flexibility to increase contributions beyond the minimum for employees and employers.

PART 5 CENTRAL PROCESSING AGENCY The creation of the Central Processing Agency to act as the State monopoly on auto enrolment is the largest and most fundamental change to the proposals as set out within the Pensions Strawman.
The Pensions Strawman had a proposal for there to be four private registered providers who would provide choice, flexibility and options to consumers by using their extensive pensions knowledge, experience and systems.

Charges would be capped at 0.50% of assets annually, services levels would be set out in legislation and customers could choose their provider based on service, fund choice and member engagement.

All costs of establishment would rest with the four chosen providers.
This approach was the one favoured in the UK, US, Australia and New Zealand who chose to use their existing pensions systems to complement AE.

Irish Life recognise that some form of Central Agency would be required but having studied the KiwiSaver system in New Zealand believed that an expansion of the role of the Revenue Commissioners could be the most efficient, less costly and the least administrative burden for both employers and the State.
However, the heads of Bill have instead chosen to eliminate all choice and competition for the consumer and instead create a new State body that will act as a monopoly in the AE market.

It is noted that the Central Processing Agency will be established via a loan from the Minister.

There is no financial analysis of the cost of this loan.

However, it should be noted that a similar loan was provided to the UK equivalent NEST which was over £600m for its establishment.
In addition, even though the UK does allow for competition in the AE market with pensions providers, the loan to NEST was subject to state aid approval by the European Commission due to the possible impact it could have on the UK pensions market.

It is assumed therefore that any similar loan to the CPA will also be subject to EU State aid approval and that its terms will be such to create a level playing field with occupational pension schemes.
No cost benefit analysis has been provided as to why a new State monopoly has been created and why existing pensions systems already within the market could not be re-utilised as envisaged within the Pensions Strawman.
While it is stated that trust in the system must be mediated by a non-profit State 6 agency this must be balanced against the removal of all choice and flexibility to the consumer on who they invest their money with, the level of savings that they make and the service levels that will be provided.

Will the CPA match the levels of disclosure and digital experience that is currently provided to occupational scheme members?
If members are unhappy with the investment choices, level of information or service levels they receive they will have no options.

Also if the State choses to increase their charges they will have no other options but to remain with the State provider.

It is notable that the Heads of Bill do not specify any cap or level of charging to apply to the AE bill albeit the Strawman was clear it should be set at 0.50% of assets annually.
The exclusion of existing pensions providers and the creation of a State monopoly also raises European Competition law concerns, in particular around the freedom to provide services and the freedom of establishment.

The CPA will be a direct competitor with other occupational pensions schemes, but with a mandatory opt-in and more preferential financial incentives for some consumers.
The possible EU competition implications of this model need to be explored together with the possible impact on the occupational schemes model into the future.

There is also a danger that as customers will have little to no choices or flexibility that they will not engage with their pensions pots and will merely see it as another form of tax.

While Head 16 sets out that there will be a board of directors of the CPA it is not clear how the AE scheme will of itself be established.
It is assumed that the AE scheme will be structured as a master trust and subject to all the same governance rules as set out under IORP II 5 that apply to other Master Trusts in Ireland.

It is notable that the Minister for Social Protection when transposing the IORP II directive chose to apply it to all schemes regardless of size, including single member schemes – due to the protects and governance structures that were deemed necessary for all members.
As the AE scheme will be the largest pension scheme in the State it is assumed that all the provisions of IORP II will apply, from the fitness and probity of trustees, to capital requirements and disclosure obligations.
It is believed that a reversion to the model set out within the Pensions Strawman would be:  Quicker through the use of existing pension provider systems;  Cheaper as it would be funded primarily by pensions providers;  Provide choice, flexibility and ownership to AE members of their pension pots;  Would introduce competition on service, product, investment and charging for customers.
5 The European Union (Occupational Pension Schemes) Regulations, 2021 (the Regulations) 7 Recommendations on PART 5: • A cost benefit analysis on the impact to the State of establishing and creating a State monopoly for AE over the use of existing pensions providers; • The speed of implementing AE should be assessed between the AE model and the use of pensions providers; • The benefits of a State monopoly should be considered against the reduction in choice, flexibility and competition provided to consumers; • A regulatory impact assessment of should be carried out on the CPA as set out in the heads of Bill against the proposal within the Pensions Strawman.
• Any loan to the CPA should be referred to DG Competition for approval – the cost and time of this loan should be reviewed against a reversion to the Strawman proposal.

• The use of the Revenue Commissioners should be assessed rather than the creation of a new State Agency.

• The impact of the CPA on occupational pensions schemes needs to be considered.
• Members of the AE scheme should have all the protections, disclosures and governance afforded to members of occupational pension schemes under IORP II.

Head 25 & 29 This provision shifts the onus of calculating contributions to the employer.

This will add complexity and administrative burden, in particular where the employer has to maintain both an AE scheme and an occupational scheme.

It would be better if this was to revert as previously stated to the Revenue Commissioners.
PART 7 – INDIVIDUAL ACCOUNTS Head 31 & 32 While it is stated that the CPA will maintain individual accounts and that the Minister will make regulations on this basis no further information is provided.

The AE scheme should be subject to all the same regulatory protections and governance as all defined contribution occupational pension schemes.
This level playing field between AE members and occupational scheme members should be clearly set out within the AE bill and should include all the same disclosures that those to apply to occupational scheme members.

If the CPA is to act as the State monopoly it should afford scheme members all the same information they would have received from pensions providers.
Recommendations Head 31 & 32: • Clearly set out that the AE scheme shall be subject to all the same accounting, governance and disclosures that apply to defined contribution occupational scheme members.

8 PART 8 – INVESTMENT PROFILE AVAILABLE TO AE PARTICIPANTS Head 33 & 34 The AE scheme is to provide for four fund types the default fund, conservative fund, moderate risk fund and higher risk fund.
These investment strategies will be set out by the Minister in regulation and then the mandate will be given to four investment managers who will then provide a blended return.

However, there is no specification within the AE bill of any advice being provided by the CPA to members of AE of what strategy they should follow based on their own personal situation and needs.
Best practise for pensions providers is to offer an assessment of members needs and risk preferences and assist them with advice on their investment options.

Also as the CPA will be managing every aspect of the AE system including selecting the investment managers, setting out the investment strategy and issuing the mandate to each investment manager.
Hence for each fund there is a possible State liability as members will expect the CPA to take full responsibility where a strategy does badly against similar market strategies.

In particular where AE members are precluded from moving to another pensions provider.
Recommendations on Head 33 & 34: • Investment advice should be offered to all AE members to allow them select the most appropriate fund for their age, gender, financial position and circumstances; • The default fund should take into account the age profile of members within its parameters and include life-styling concepts similar to those utilised already by pensions providers.
• Revision to the Strawman proposals would allow members more choice of investments, advise and would minimise State liability as pensions providers would bear the advise risks.

• All the guidance, rules and consumer protections applicable to pensions providers as issued by the Central Bank of Ireland need to be equally afforded and implemented to auto enrolment members i.e.

ongoing financial, life time advise.


PART 11 COMMUNICATION AND INFORMATION As a general principle all communication and information provided to AE members should be the same as that provided to all defined contribution occupational scheme members.

AE members should have all the same protections and disclosures applied to occupational scheme members.

The digital portal will require the use of MyGovID for implementation.
Recommendations on Head 42 – 46: • The Bill should clearly specify that AE scheme members will receive all the same disclosures and information provided to defined contribution occupational scheme members.

• All the guidance, rules and consumer protections applicable to pensions providers as issued by the Central Bank of Ireland need to be equally afforded and implemented to auto enrolment members i.e.

ongoing financial, life time advise.


9 PART 12 COMPLIANCE Head 48 provides that the CPA will act as the regulator in relation to employers compliance with the AE system rules.

This would seem to duplicate the functions of the Pensions Authority who is the regulator for occupational pension schemes.

The Pensions Authority has the expertise, tools and resources to carry out this function but would appear to be replaced in this instance with the CPA.
In the event that an employer has both an occupational scheme and an AE scheme it would appear that two sets of regulators would be applicable applying similar if slightly differing rules.

Recommendation on Compliance: • The Pensions Authority should be the regulator for AE similar to occupational pension schemes.

PART 14 SUPERVISION Head 56 The Pensions Authority is the competent authority to regulate the CPA under IORP II.
This would mean that there are two layers of regulation applicable: one for the CPA overseeing employer compliance and then compliance on this Compliance.

This differs entirely for the position for every other occupational scheme in the State of for Master Trust regulation.

The Pension Authority should ensure both Compliance and Supervision of the CPA two layers of differing regulation purely replicates work.
The Pensions Authority is a statutory authority which reports to the Minister for Social Protection.

The CPA will also be a statutory authority established under the Minister of Social Protection.

The Minister for Social Protection will therefore be the ultimate regulator for pensions industry via the Pensions Authority and the ultimate shareholder of the CPA which will compete with the pensions industry.
The Pensions Authority will effectively be regulating its sister statutory body under the auspices of the same Minister.

The Minister for Social Protection also sets pensions policy and will determine the charges applicable to the CPA when competing against other pensions providers.

In addition, the Minister is also responsible for the State Pension.

This would seem prima facie to raise issues of conflict of interest for the Minister and for the Pensions Authority.
Recommendations Head 56: • The potential conflicts of interest of the Minister for Social Protection need to be assessed; • Reversion the Strawman model would eliminate this conflict of interest; • Consideration of the role of the Central Bank of Ireland should be assessed.

PART 15 RETIREMENT BENEFITS Head 58 One of the general goals of pensions policy in recent years has been around simplification.
The government’s own Interdepartmental and Pensions Reform and Taxation Reporting group states: 10 Reform and Simplification: “The supplementary pension system, which is comprised of Second Pillar trust-based occupational schemes and Third Pillar contract-based personal pension products, is undoubtedly complex for consumers to navigate.
The availability of multiple pension savings vehicles providing retirement benefits and inconsistencies between the rules applying to different arrangements, are among the factors that can cause confusion and may discourage individuals from engaging with the system.

The taxation treatment of the different supplementary pension saving arrangements has evolved in an ad hoc manner over time.
This arises largely due to separate pension policy and tax policy related decisions and has resulted, for example, in the tax treatment of contributions, lump sums, and death-in-service benefits becoming a complicated function of an individual’s employment status and their choice of pension saving vehicle.” Despite the above, the draft Bill introduces further complexity by suggesting that all AE benefits be made available as a lump sum for a temporary period.
This is very different to the Defined Contribution rules.

This is also in stark contrast to the original strawman which noted “a minimum level of annuitisation may be mandated”.

The argument that this is purely a temporary measure and hence immaterial is not sound: a new joiner to the AE plan at say age 30 will need clear communication of the rules that will apply upon retirement and will rely on those rules for making retirement planning decisions.
A new entrant will compare the AE system to an alternative Defined Contribution (DC) plan where there are more restrictions on the point of retirement and make decisions based on this comparison.

It’s critical that there is a level playing field and we maintain simplicity and consistency.

As the example below shows, for some about 10 years from retirement, the differences can be material.
Assessing in more detail, the DC rules allow a lump sum of either 25% of the fund or up to 150% of their final salary after 20 years of service (or 45% of final salary after 10 years).

The remainder must be taken as an annuity or invested in an ARF.

The AE rules give 100% lump sum regardless.


Example of difference between AE and DC for a sample member with 10 years’ service Salary at retirement: Fund at retirement: €40,000 €30,000 AE Approach Lump Sum €30,000 DC Approach 25% of Fund Lump Sum Remaining Fund Option for Remaining Fund 25.00% €7,500 €22,500 Annuity or ARF OR 45% of Salary 45.00% €18,000 €12,000 Annuity Only The AE 100% rule means the AE is more attractive giving greater flexibility versus the DC plan.
Whilst the plan might be to change this in time, the initial product material will show clear difference of treatment in projections over the 10-year term.

There are also no specification on how pension adjustment orders will be applied over auto enrolment pots and how the CPA will manage these.
11 Recommendation on Head 58: • The Bill should clearly specify that retirement benefits will align to those provided to occupational pension schemes; • Clarity needs to be provided on the form of taxation to be applied to pensions pots in retirement so that member can make proper provision for the future over the long term.

• Transparency on the application of Pensions Adjustment orders needs to be provided.
PART 18 – AUTO-ENROLMENT FEES AND CHARGES Head 64 The initial strawman had a proposed cap of 0.50% of assets annually set out which was to operate for pensions providers.

The current Bill has no cap in place for the CPA and provides no level of certainty as to what charges will be imposed on members.

There is no proposed benchmarking against charges for large master trusts in a similar position.
There is also no benchmarking of the costs incurred by the establishment of the CPA and administration against private sector equivalents i.e.

staffing costs, administration etc.

The Auto Enrolment scheme must be self-financing rather than reliant on additional funding from the Exchequer which is not available to occupational scheme member.
While it is provided that the Minister will set the cap via regulation, it is unclear how this mechanism will operate as the charge is effectively a money bill and therefore should be implemented by primary legislation.

For certainty for members it should also be set out against primary legislation.
The charge to be applied would also need to be carefully monitored to ensure it covered costs, as if, additional State funding was required this would be subject to EU competition rules to ensure there was no below cost charging by the dominant state monopoly.
Recommendation on Head 64: • Reversion to the Strawman proposal would allow for the establishment of a cap but also for charging competition between providers; • Any cap should be set out in primary legislation and benchmarked against Master Trust charges and costs.

• The charges should ensure that the auto enrolment scheme is self-financing as was envisaged within the Strawman.
A cost benefit analysis should also be carried out to ascertain how much additional cost will be incurred by members through the use of a State CPA rather than under the Strawman model.

12 PART 19 Head 66 – Transfer of existing pension fund into the AE system This head prevents the amalgamation of pension funds and effectively prevent ‘Pot follows the member’.

Currently within occupational pension schemes all members can chose to consolidate their DC pension contributions into one pot.
This simplifies their pension arrangements and allows ease of reporting.

With the revised AE system and the use only of a State player an employee is likely to have multiple pots across a number of employments.

This causes further confusion and adds to complexity.
Recommendation on Head 66: • Reversion to previous Strawman would mean that an employee while unable to consolidate pots could get an amalgamated view of pots if they were all with the same pension provider; • Reversion to the previous Strawman would mean employers would also have one view of the entirety of the pension funds between AE and occupational schemes where held by the one provider.
Conclusion The introduction of Auto Enrolment will mean a step change in securing better retirements for all in Ireland and as such it should be implemented as quickly and efficiently as possible.

On one day in 2024, 750,000 will suddenly be enrolled in the largest pensions scheme ever created in the State, it is therefore imperative that this is done correctly and with the best interest of the member at its core.
However, the necessity for Auto Enrolment should not be at the expense of remedying gender inequality and the elimination of consumer choice.

Women in Ireland already face a multitude of obstacles to reach pensions parity with men, the State should not be implementing a system which embeds this discrimination for generations to come and removes any chances of improvement.
Cost, flexibility and gender concerns have all stemmed from the change implemented from the Strawman which would have allowed competition in auto enrolment to the establishment of a State monopoly.

Irish Life is strongly of the belief that the auto enrolment scheme could be implemented quicker, cheaper and with more benefits to the consumer by a reversion to the proposal within the Strawman model rather than the establishment of the CPA.
Irish Life would like to again thank the Committee for the opportunity to participate in this vital and key consultation that will impact the Irish Pensions world for generations.

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