My Future Fund launched on 1 January 2026 and the first six months have gone quietly for most employers. That changes in July. Employees enrolled from January can exercise their right to opt out from month six — meaning July and August 2026 for the first cohort. Here is what you need to know, what NAERSA requires you to do, and the mistakes that are already resulting in penalties for early non-compliant employers.
⚠️Timeline: the opt-out window for January 2026 enrolments
Employees enrolled from 1 January 2026 enter their opt-out window in July 2026 (month 6). The window closes at the end of August 2026 (month 8). After that, employees cannot opt out until the next contribution rate change, which occurs in January 2029.
What the opt-out right actually means — and what it doesn't
Under the Automatic Enrolment Retirement Savings System Act 2024, employees have a right to opt out between months 6 and 8 of enrolment. This is not a general right to cancel at any time — it is a specific, time-limited window.
When an employee opts out within this window:
- Their own contributions are refunded in full
- Employer contributions are not refunded — they remain in the employee's My Future Fund account and continue to be invested
- Government (State) contributions are not refunded — same
- The employee is automatically re-enrolled after 2 years if they still meet the eligibility criteria
- They can suspend contributions (rather than opt out), which pauses deductions but does not trigger a refund
This is an important distinction: an opt-out is not an exit from My Future Fund. It is a pause in contributions with automatic re-enrolment built in.
ℹ️What employers cannot do
Employers are legally prohibited from encouraging, pressuring, or incentivising employees to opt out or suspend contributions. This includes any conversation that suggests opting out would benefit the employer financially. It is a criminal offence under the AE Act 2024 and can result in prosecution, fines, and WRC claims from employees.
The employer's role in the opt-out process
This is where many employers are not yet up to speed. The opt-out process is not entirely handled by NAERSA on your behalf. Employers have active obligations that must be met correctly within the payroll cycle.
Step 1: Employee notifies NAERSA directly
The opt-out process begins with the employee — they notify NAERSA via the MyFutureFund participant portal using their verified MyGovID. Employers do not need to receive or process the opt-out request directly.
Step 2: NAERSA issues a new AEPN to your payroll
Once NAERSA processes the opt-out, they issue an updated Auto-Enrolment Payroll Notification (AEPN) to your payroll system. This AEPN reflects the change in the employee's status. Your payroll software must retrieve this updated AEPN at the next pay run.
Step 3: Stop deductions from the correct pay date
From the pay date after the updated AEPN is received, you stop deducting that employee's contributions. The timing matters — continuing to deduct after NAERSA has processed the opt-out creates an obligation to refund and can trigger a NAERSA intervention.
Step 4: Refund processing
The employee's own contributions up to the opt-out date are refunded. NAERSA coordinates this through the payroll system — the specific mechanism depends on your payroll software's integration with NAERSA's systems. If you are using a managed payroll service, your provider should handle this end to end.
Step 5: Record the opt-out and set re-enrolment reminder
You are required to maintain records of opt-outs and re-enrolment dates. The employee must be automatically re-enrolled after 2 years — in July 2028 for those who opt out in July 2026. This is not NAERSA's responsibility to chase. It is yours as the employer.
| Action | Who does it | Timing |
|---|---|---|
| Notify NAERSA of opt-out decision | Employee (via MyFutureFund portal) | Months 6–8 of enrolment |
| Issue updated AEPN to payroll | NAERSA automatically | After opt-out is processed |
| Retrieve new AEPN, stop deductions | Employer / payroll provider | Next pay run after AEPN issued |
| Process employee contribution refund | NAERSA / payroll provider | Per NAERSA schedule |
| Record opt-out in payroll records | Employer / payroll provider | Immediately |
| Re-enrol employee after 2 years | Employer (NAERSA sends AEPN) | July 2028 (for July 2026 opt-outs) |
What happens if you don't stop deductions when notified of opt-outs correctly
Continuing to deduct contributions after NAERSA has processed an employee's opt-out is an employer compliance failure. Under the AE Act, this can result in:
- NAERSA compliance intervention
- Fines of €5,000 to €50,000 per offence
- Interest charged on any overdue refunds
- Your business listed on NAERSA's public register of non-compliant employers
- WRC claims from affected employees
The public register is a particularly significant consequence for SMEs — it is visible to clients, suppliers, and prospective employees.
The pre-opt-out period: what to prepare now
Before July arrives, there are practical steps every employer should take. These are not complex — but they do require your payroll system and processes to be set up correctly.
- Confirm your NAERSA employer portal is active and your direct debit is set up correctly
- Verify your payroll software is retrieving AEPNs at every pay run (not just on first setup)
- Check that your current AEPN reflects the correct employee list and contribution rates
- Make sure your payroll person or provider knows the opt-out process and what to do when an AEPN changes status
- Identify any employees who might be likely to opt out and ensure their records are complete
- Set a calendar reminder to re-enrol any July/August 2026 opt-outs in July/August 2028
- Prepare a short, neutral employee communication about the opt-out right — providing factual information without discouraging participation
Not sure if your setup is ready for July?
CBCR Payroll runs free 30-minute auto-enrolment health checks for Irish employers. We'll check your NAERSA registration, your AEPN retrieval process, and your opt-out readiness — and tell you exactly what needs to be fixed before the window opens.
Common mistakes employers are already making in 2026
Six months into My Future Fund, the IPASS-certified team at CBCR has seen the same errors appearing repeatedly across Irish businesses of all sizes:
- Not retrieving AEPNs at every pay run. Many businesses retrieved the initial AEPN in January and haven't touched it since. AEPNs change whenever an employee's enrolment status changes, including opt-outs, new starters, and status corrections. If you're not retrieving them every cycle, you're running on stale data.
- Missing the the required deadline The contribution submission must reach NAERSA on time each pay date
- Excluding bonuses and overtime from contribution calculations. Contributions are calculated on total gross pay, including overtime, commission, bonuses, and benefit-in-kind — up to the €80,000 annual cap. Calculating only on base salary is one of the most common errors.
- Registering on NAERSA but not managing the ongoing process. Registration was a one-time task. The ongoing obligations — AEPN retrieval, AECS submissions, stopping deductions when notified of opt-out — are recurring payroll tasks. They do not manage themselves.
- No process for noting that re-enrolment is managed by NAERSA. Every opted-out employee must be re-enrolled after 2 years. Without a formal tracking process, this will be missed — and missing re-enrolment is a compliance failure.
Should you outsource auto-enrolment management?
The honest answer depends on the complexity of your payroll and the capacity of your in-house team. For businesses running payroll themselves or through an accountant not specialist in payroll, the recurring nature of auto-enrolment obligations creates meaningful ongoing risk.
CBCR's managed payroll service includes full auto-enrolment management as standard — NAERSA setup, AEPN retrieval at every run, AECS submissions on time each pay date
If you are managing auto-enrolment in-house and are confident your processes are correct, the checklist above is a useful benchmark. If you have any doubt about whether your setup is actually running as it should — the free health check is the fastest way to find out.
About the authorThis article was written by the CBCR Payroll Solutions team. CBCR is an IPASS-certified payroll outsourcing practice based in Swords, Dublin. We provide managed payroll services for Irish SMEs across Healthcare, Construction, Finance, Logistics, Aviation and IT. Contact us at Send us an email or 01 566 5247.