In March 2025, our Pensions and Employee Benefits Group co-hosted an Auto-enrolment & Master Trust event with Zurich at the Shelbourne Hotel, Dublin. The seminar was attended by over 100 employers and focused on the topical issues of pensions auto-enrolment and master trusts. The event included contributions from:

• Deirdre Cummins and Daniel Watters of Arthur Cox joined by Joe Creegan of Zurich to discuss auto enrolment;
• Richard Temperley of Zurich on investing for value; and
• Sarah McCague of Arthur Cox joined by Francis Coll, Graham Cashell and Conal O’Regan of Zurich on the process of moving in and out of master trusts.

Auto-enrolment

Deirdre Cummins, Of Counsel in our Pensions and Employee Benefits Group, provided an overview of the pensions auto-enrolment system (the “AE System”) that is due to be introduced in Ireland with effect from 30 September 2025. From that date, employees aged between 23 and 60 who earn in excess of €20,000 per year and who are not already enrolled in an occupational pension scheme will be automatically enrolled into the AE System. Deirdre Cummins noted that a number of important aspects of the AE system are to be set out in regulations that are yet to be published, so employers were encouraged to continue closely monitoring developments in this area.

As part of the panel discussion, Deirdre was joined by Daniel Watters, Partner in our Pensions and Employee Benefits Group and Joe Creegan of Zurich. Daniel Watters outlined the main differences between occupational pension schemes and the AE System. Among the differences highlighted were that employee contributions to occupational pension schemes are subject to tax relief at source, whereas the AE System operates a “State top-up” that has been stated to be broadly equivalent to 25% tax relief. It was also noted that the AE System, as currently designed, does not facilitate additional voluntary contributions, special employer contributions or early retirement (other than in cases of ill-health).

With the 30 September 2025 implementation date fast approaching, employers were encouraged to take action now to begin preparing for auto-enrolment. Daniel Watters recommended that employers undertake a gap analysis of their workforce to see who is covered by a pension arrangement and who is not. Employers will then need to decide whether (i) they wish to ensure all employees are included in their occupational pension scheme; (ii) they want the AE System to apply to all employees; or (iii) they want to operate both systems in tandem for different cohorts of employees. Once this decision is taken employers will need to take steps to prepare for auto-enrolment going live, including reviewing contracts of employment and relevant employment policies as well as potentially amending existing pension arrangements.

To keep up to date on the introduction of automatic enrolment in Ireland, you can subscribe to our auto-enrolment portal here.

Master Trusts

Sarah McCague provided an overview of the legal considerations for employers exploring a transition to a master trust. Master trusts are multi-employer, defined contribution schemes established under trust. Many employers are winding-up their occupational pension schemes and transferring to master trusts in response to the increased regulatory burden imposed on standalone occupational pension schemes by IORP II.

Sarah McCague noted that the master trust transition process can give rise to a number of legal and practical issues. Among the issues raised were that: (i) standard documents used by master trust providers may need to be amended to cater for bespoke benefits or membership categories, particularly if employers wish to establish new membership categories in light of the introduction of auto-enrolment; (ii) there remains uncertainty over the extent to which Pension Adjustment Orders (“PAOs”) issued to the trustees of standalone occupational pension schemes continue to be applicable if that scheme subsequently transfers to a master trust; and (iii) to ensure accountability of master trust providers, employers may wish to establish an employer oversight committee for their section of the master trust.

Sarah McCague also reminded employers who have transitioned to master trust to ensure that their legacy occupational pension schemes have completed the wind-up process and that this has been properly documented and notified to the Pensions Authority. Sarah McCague was joined by Francis Coll, Graham Cashell and Conal O’Regan of Zurich for a discussion on risk management and cyber security in the Zurich Ireland Master Trust as well as the process of transitioning employers into that master trust.

If you would like to discuss the topics of pensions auto-enrolment or master trust transitions in more depth, please reach out to a member of the our Pensions and Employee Benefits Group.