Auto-enrolment doesn’t end once you’ve set up your pension scheme and enrolled your workforce. For most employers, there are ongoing obligations that come around every three years, and missing them can lead to fines from The Pensions Regulator (TPR).
Yet re-enrolment, declarations and re-declarations are probably the least talked-about part of the whole auto-enrolment framework.
What is re-enrolment?
Re-enrolment is the process of putting certain workers back into your pension scheme. It happens every three years, on a date that falls within a six-month window around the third anniversary of your original staging date or duties start date.
You have some flexibility over when exactly you complete re-enrolment within that window – three months before the anniversary, on the anniversary itself, or up to three months after – but you do need to choose a date and act on it.
The reason re-enrolment exists is straightforward. Auto-enrolment legislation recognises that employees have the right to opt out of pension saving, but it also recognises that people’s circumstances change. Re-enrolment is the mechanism that gives workers who opted out a fresh opportunity to participate, without
them having to take any action themselves.
Who needs to be re-enrolled?
Not everyone on your payroll needs to be assessed at re-enrolment. You only need to re-enrol workers who meet all of the following conditions.
- They must be aged between 22 and the state pension age
- They must be earning above the earnings trigger for auto-enrolment, which in 2026/27 remains at £10,000 a year
- They must be working in the UK
- They must not currently be an active member of your qualifying pension scheme
That last point is the key one. If an employee never opted out, they’re still in the scheme, and there’s nothing to do. Re-enrolment is specifically about bringing back those who previously opted out, or who ceased active membership for any other reason.
There are some workers you do not have to re-enrol, even if they would otherwise qualify. These include workers who opted out or ceased active membership within the 12 months before your re-enrolment date, and workers who have given you a valid notice of leaving the scheme or applied for a pension protection status.
Checking each individual’s position carefully before re-enrolment is important – re-enrolling someone who is exempt creates unnecessary administration for everyone.
Once you’ve identified the eligible workers, you must re-enrol them and write to them within six weeks of your re-enrolment date to let them know what has happened and what their options are. They are entitled to opt out again if they choose to.
What is a Declaration of Compliance?
When you first set up auto-enrolment, you are required to tell TPR what you’ve done. That is your Declaration of Compliance – sometimes called your initial declaration.
It confirms that you have met your employer duties, including that you have enrolled eligible workers into a qualifying pension scheme, that you are paying the correct contributions, and that you have completed all the necessary administrative steps. It’s essentially your formal statement to the regulator that you’ve
done what the law requires.
You complete the declaration using TPR’s online system, and you must do so within five calendar months of your staging date or duties start date. Failing to submit in time is one of the most common compliance issues TPR encounters, and it is one of the things that can prompt a compliance notice or fixed penalty.
The declaration asks for information, including your employer’s PAYE reference, the name and contact details of whoever is responsible for pensions at the business, details of your pension scheme, and the number of workers you’ve enrolled.
What is a Re-Declaration of Compliance?
Three years on from your initial declaration, after you’ve completed re-enrolment, you need to submit a Re-Declaration of Compliance. This works in much the same way as the original declaration, but it confirms that you have fulfilled your re-enrolment duties.
You must submit your re-declaration within five calendar months of your re-enrolment date. So if your re-enrolment date is 1 May, you have until 30 September to complete it. Miss that window and TPR may issue a compliance notice, and if you still don’t act, a fixed penalty of £400 follows.
The re-declaration covers broadly the same ground as the initial declaration. You’ll need to confirm
- How many eligible workers were re-enrolled
- Whether there were any workers you weren’t required to re-enrol, and why
- Confirm that your pension scheme continues to meet the qualifying criteria.
Even if you had no workers to re-enrol, because everyone who was eligible had opted out within the previous 12 months or was already in the scheme, you still need to submit the re-declaration. It’s a mandatory filing regardless.
The deadline that’s easy to miss
One of the most common re-declaration problems we see isn’t a business deliberately ignoring its obligations. It’s a business that simply didn’t realise the three-year cycle had come around again. If you’re not tracking your staging date anniversary and your re-enrolment window, it’s surprisingly easy for the
deadline to creep up.
TPR does write to employers in advance, but those letters can get lost in the day-to-day flow of running a business, particularly in smaller organisations where payroll and HR responsibilities sit alongside everything else.
If you’re unsure when your next re-enrolment date falls, you can check via TPR’s online tools using your employer PAYE reference. Or, if you work with Ascend Payroll, we’ll keep track of it for you.
How Ascend Payroll can help
Managing the pension obligations that sit around auto-enrolment, including the assessments, re-enrolments, declarations and the communications to employees, is a regular part of what we do for our clients. We don’t just process payroll; we make sure the compliance that runs alongside it is handled properly and on
time.
If you’re approaching a re-enrolment date, or you’re not sure when yours falls, get in touch with the Ascend team, and we’ll talk you through it.
