Mr. Fergal O'Brien:

I thank the Senator. We have a number of points to make with regard to the timelines. First, from an employer perspective, I will go back to my point about labour costs certainty. We are working with businesses that will probably be doing their budgets for 2024 in the next three to four months. They are going to be trying to figure out what their businesses can afford with regard to increases in labour costs and hiring decisions. That is what it comes down to. It comes down to what the labour costs bill is going to be. If they are not given certainty in good time as to when something like this is going to be introduced, they will have to make knee-jerk responsive decisions in their businesses further down the road, which could potentially impact on employment. In our view, businesses should have a two-year lead-in period from the Bill being passed and signed to allow them to be ready. That is our main ask of the committee.

While we do not present ourselves as the experts on this issue, from other engagements with the State, we do observe that there will be particular challenges with regard to the proposal for a central processing authority, CPA. It seems to us that this will be a very complex organisation involving technology and an administrative system that will need to be established. Everything we know of public policy and the establishment of similar agencies in the past suggests that this will take some time, that it will be complicated and that there will be teething problems. We have always identified that we have a really high functioning arm of the State that already engages with every employer in the State every day or every week, Revenue. We fail to see why Revenue is not the optimal arm of the State to collect these contributions. Employees and employers have trusted and established relationships with Revenue and the payroll and Revenue technology are in place. To us, collection could have been the simplest and most straightforward element. We would then obviously need to look at the other elements, including regulation, administration and investment.

To reiterate my two points, we request that the committee support us in ensuring that employers have a two-year lead-in from the completion of the legislation so that they have certainty in planning for their businesses and we have some concerns with regard to the complexity of the CPA in particular.