Ms Aoife McFadden:

IBEC does not agree with the fact that there is no waiting period. The general scheme's rationale, precluding the use by employers of probationary periods or short temporary contracts as a means of avoiding auto-enrolment obligations, is not something we agree with. Many occupational pension schemes include waiting times, which are aligned with the probationary period specified in the contracts. The proposal set out in the general scheme is inconsistent with this practice. For example, section 121 of the Pensions Act requires an employer who is not operating a scheme or operating a scheme that imposes as a waiting period for membership of it a period that is longer than six months must provide mandatory access to a PRSA. This is aligning. We feel the general scheme is not aligning with the current practices. We have a substantial level of private-sector provision that should be preserved and not destabilised by the reforms proposed within the general scheme. If adopted, head 5, under which the waiting period is addressed, or no waiting period is addressed, could create an anomaly whereby a new employee would be required to enrol in the auto-enrolment system and then switch to an occupational pension scheme. We suggest that this uncertainty be addressed. Drafting certainty and policy certainty are so important for employers, as we have outlined. We ask that this be examined as well.