Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697803787501.pdf (Ireland)
General Scheme of the Automatic Enrolment Retirement Savings System for Ireland Bill 2022 The Association of Pension Trustees in Ireland welcomes the opportunity to make a submission, we have the following observations on some parts of the Draft Heads and General Scheme of the Bill.

Automatic Enrolment – criteria set The legislation refers to a qualifying occupational pension scheme.

We feel it is important that it is clearly defined what is to be deemed a “qualifying occupational pension scheme”.
It should be extended to include Personal Retirement Savings Accounts (PRSAs) where both the employer and employee are actively making contributions to the PRSA.

Occupational pension schemes also exist where an employer makes contributions to a pension arrangement that are in excess of the total contributions required under the auto- enrolment scheme but the employees of the employer don’t have to contribute to the scheme.

Such arrangements should also be deemed to be qualifying schemes.
Many current occupational pension schemes have deferred periods where, say, the employee can only join the pension scheme at the end of their probation period with the employer.

This is usually a 6 month period.

Again we feel such schemes should be considered qualifying schemes.

In terms of the age limits that have been set, we feel there should be no minimum age limit on the entry age to the auto enrolment scheme.
There is a big push from government at the moment in relation to apprenticeships (Generation Apprenticeship) and we are starting to see a number of apprentices enter our own industry where the “earn and learn” scheme is being promoted by the Life Insurance Association and the Insurance Institute of Ireland.
As a result we are likely to see a large number of 18 plus year olds entering the workplace under apprenticeship schemes and as such we feel the savings habit should be introduced to them straight away with the ability to join the auto enrolment scheme.

They should not be excluded as a result of a lower age limit being imposed.

Lump Sum Clarification is needed in relation to a number of areas relating to the provision of a lump sum under the auto enrolment scheme.
We have noted some comments below: • There are currently clear rules in place as to how pension lump sums from other pensions an individual has impacts on their retirement benefits when they draw down their pension benefits.

No indication is given how such a lump sum under the auto enrolment scheme would impact on future retirement benefits an individual may draw down from other pension arrangements.

This needs to be clarified.


• When individuals retire they typically look for an income in retirement which is the whole basis of pension provision.

If allowance is given for all of the benefits from the scheme to be taken as a cash lump sum then this goes against the purpose of planning appropriately for retirement.

• It is important there is fully clarity in relation to the benefits individuals can receive at retirement.
There appears to be confusion in that those auto-enrolled may be able to take benefits as a tax-free lump sum whereas others, at some time in the future, may not have this option which is not equitable.