Somewhat surprisingly, the numbers of fixed penalty notices issued to employers has dropped, and there were no escalating penalty notices at all in the period 01.04.15–30.06.15. To the casual reader, this therefore may suggest that more overt policing of the new AE duties has resulted in a greater level of employer compliance. This may well be the case, yet even the regulator expects the numbers to be on the rise again once the large swathes of smaller employers are required to comply in 2016 onwards.
Another point of note is that the number of unpaid contribution notices has significantly increased in the last quarter. This may suggest that employers who have initially complied with AE duties may subsequently be failing to keep on top of this task, and are then failing to pass the contributions to the selected pension scheme(s) within the correct timescale. This is another reminder that compliance with AE duties is not a one-off event, and in fact is a continuous process for all employers.
We will continue to monitor these reports and will update the blog as appropriate. Employers seeking more information on AE duties should speak to their usual Jelf consultant in the first instance.