CIPP response to the DWP consultation on technical changes to Automatic Enrolment

This was a lengthy consultation document and the timescale for responding was very short so firstly, the CIPP Policy team would like to thank everybody who took the time to respond over the holiday period.

CIPP members broadly agreed with the proposals to simplify processes. However, genuine concerns remain that, unless great care is taken when forming the detailed processes, they will actually become more complicated rather than being simplified. The key findings from our research are:

• Of all the proposals, there was least certainty about the minimum amount of information an employee should be given.
• Less than two thirds agreed that required information could be given in one communication.
• Only 29% agreed that it would remove the need for continual assessment.
• There was more support for combining postponement information with 73% agreeing that this would reduce the burden on employers.
• 83% of respondents agreed with the suggestion that there is no need to write to existing members of a qualifying scheme.
• There was strong agreement (89%) with the proposal to standardise enrolment letters for all employees, yet only 53% believed that employees would receive all the information they needed from a standardised letter.
• 75% of respondents agreed it would be useful to give employees details of where to obtain an opt-out notice.
• 76% agree that the aspiration of communicating three pieces of information is realistic.
• There is less certainty as to whether this raft of proposed changes would cause confusion for employees, with only 58% believing there will be no detriment for employees.
• 77% of respondents agreed with the suggestion that employers can choose whether to enrol someone who has handed in their notice.
• 67% said they didn’t foresee problems with removing opt-in rights from employees during a notice period.
• Opinion was equally divided as to the frequency of notice withdrawal and whether the exception should be extended to fixed term contracts.
• 70% of respondents agreed with the proposal that employees who have recently cancelled qualifying scheme membership, whether new joiners or not.
• 72% of respondents agreed with the wide exception to automatically enrolling employees with tax protected status.