In November 2022, Insurance Ireland submitted a detailed response on the General Scheme of Automatic Enrolment Bill to the Joint Committee on Social Protection, Community and Rural Development and the Islands and was pleased the majority of the issues raised as part of the submission were addressed in the recommendations of the Committee’s Report on Pre-Legislative Scrutiny of the General Scheme of the Automatic Enrolment Retirement Savings System Bill 2022 (hereinafter the Bill).

Since that publication and the recent publication of the Bill, however, Insurance Ireland has been disappointed that limited to no action has been taken to progress any of these recommendations. While a number of these issues with the proposed auto-enrolment (AE) system in both Insurance Ireland’s submission and the report of the Joint Oireachtas Committee remain, and Insurance Ireland calls on the Department for Social Protection (DSP) to action them accordingly, a number of further issues were identified by Insurance Ireland in an earlier iteration of this position paper.

Insurance Ireland is pleased that the Minister has taken on board, septically Insurance Ireland’s feedback in relation to consumers being able to make complaints and about the external adjudication for the AE system and that issues relating to the data sharing arrangement between the National Automatic Enrolment Retirement Savings Authority (NAERSA) have also been clarified. That said, a number of the enduring issues remains, which are detailed in the latter part of this position paper.

Considerations in response to the Publication of the Automatic Enrolment Retirement Savings System Bill 2022

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