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For employer and trustee use only. A guide to operating an automatic enrolment scheme with Aviva

A guide to operating an automatic enrolment scheme with Aviva · Overview AV221112_EPEN22C_NG08085_0419.indd 2 14/03/19 8:08 AM. 3 Aviva’s automatic enrolment service is designed

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Page 1: A guide to operating an automatic enrolment scheme with Aviva · Overview AV221112_EPEN22C_NG08085_0419.indd 2 14/03/19 8:08 AM. 3 Aviva’s automatic enrolment service is designed

For employer and trustee use only.

A guide to operating an automatic enrolment scheme with Aviva

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ContentsOverview 3

Section 1 Preparing for automatic enrolment 5

Step 1 Communicate with your workers 5

Step 2 Your automatic enrolment communications 6

Step 3 Creating new members and submitting contributions 8

Categories of worker 10

Record keeping 12

Additional information 13

Section 2 Frequently asked questions 15

Overview

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Aviva’s automatic enrolment service is designed to enable you to use your existing Aviva pension scheme to automatically enrol new workers.

As part of your automatic enrolment plans and in the lead up to your duties start date, you should have made your own choices about:

• How you will categorise and assess your workers.

• How you will provide the required automatic enrolment information (these are known as ‘notices’), to your workers.

• How you will administer opt-out, opt-in and join requests.

• How you will keep records of your automatic enrolment activities.

Aviva is not responsible for these automatic enrolment requirements.

To help you prepare your communications we will provide you with access to a website that contains samples of literature and notices you may use. It is your responsibility to distribute any communications to your workers in line with the automatic enrolment regulations.

How to use this guide

This guide explains how to use your Aviva pension scheme to automatically enrol your workers.

In each section we provide you with the information needed to successfully complete each step.

Overview

The Pensions Regulator (TPR)TPR is responsible for monitoring your compliance with the automatic enrolment legislation. They provide detailed guidance to help you understand and prepare for your new duties. We have provided a link to TPR’s website below.www.thepensionsregulator.gov.uk/doc-library/automatic-enrolment-detailed-guidance.aspx

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Overview

Issue opt-out, opt-in and join

forms onrequest from

worker

Receivemember

requests toopt out, opt in

and join

Create joiner file fornew joinersand uploadto e-serve

Supplyjobholder

informationto Aviva

Automatic enrolment

assessment

Create account in

pensionscheme

Postponementperiod

communications to new workers

Create fileof activeworkers

Submitpension

contributionsvia e-serve

Aviva

Your responsibilities

The following diagram shows you some high level activities that need to take place to ensure a successful automatic enrolment journey. You have chosen to undertake some of these activities yourself and Aviva will assist with others.

The diagram does not take into account the specifics of your scheme, nor does it provide an exhaustive list of activities. What it will show, however, is the point at which Aviva will assist in providing a service to your workers.

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You need to communicate your automatic enrolment workplace pension

Automatic enrolment will be the first time some of your workers will join a pension scheme. Clear, early communication of your programme in your workplace is important for raising awareness in the lead-up to your duties start date.

Raising awareness of automatic enrolment should ensure that when pension contributions are taken from a worker’s pay for the first time it does not come as a surprise.

Early communication of your programme will help reduce the number of queries to your payroll team and keep your workers informed about the company’s pension arrangements.

Section 1 Preparing for automatic enrolment

Step 1 Communicate with your workers

8 weeks 4 weeks 2 weeks 1 week Staging Post staging6 weeks2 weeks 1 month 2 months 3 months 4 monthsStaging

Loading the new members into the scheme on e-serve must not be done until your opt-out period has ended. For workers to be assessed for automatic enrolment, you will be required to issue your own compliant automatic enrolment communications including the postponement notice (if applicable) and the assessment notice.

Reviewing your existing records

We recommend that you complete a data cleanse exercise of the information you hold on your workers. This will ensure you have the correct details to accurately assess and communicate with them.

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Step 2 Your automatic enrolment communications

Section 1

8 weeks 4 weeks 2 weeks 1 week Staging Post staging6 weeks2 weeks 1 month 2 months 3 months 4 monthsStaging

Aviva provides you with a scheme suitable for automatic enrolment. There are a number of actions you need to take prior to enrolling a worker into your scheme. In this section we outline the recommended steps you should take prior to your duties start date to ensure you are ready for automatic enrolment.

Aviva will not issue any communications relating to automatic enrolment on your behalf. You will need to ensure all the appropriate letters and communications required by the legislation are received by your workers. These include:

Postponement letter – if you have a postponement period, you will need to issue a postponement letter when a worker enters the postponement period. The letter must contain information about when they will be assessed and the right to opt in. If you are intending to apply a postponement period, a communication should be issued to the relevant workers within six weeks of your duties start date/the date they join your employment. If you do not meet these timescales, the opportunity to apply a postponement period will be lost and you will have to assess the worker for automatic enrolment from their start date/your duties start date.

Assessment letter – you will need to issue an assessment letter to your workers every time an assessment takes place.

Assessment notice – you will need to issue an assessment notice to your workers whenever their assessment status changes. Once a worker has been assessed as eligible and has joined the scheme, or opted out, you only need to reassess the worker as part of the cyclical automatic re-enrolment review.

Assessment notices must be issued within six weeks of the workers’ automatic enrolment date.

Workers are deemed to be automatically enrolled into your pension scheme on the later of:

• the date they are advised of the terms and conditions of their plan which consists of the generic illustration and the key features document;

• the date they receive their enrolment information;

• their automatic enrolment date (duties start date, 22nd birthday, date joined service, day following end of postponement etc.).

The assessment notice must include key pieces of literature which will be sent to you via email by Aviva. These literature items are:

• A generic illustration showing what the employee might get at retirement.

• A document detailing the charges related to the scheme.

• A key features document.

Where automatic enrolment assessment notification is provided by letter, these documents must be printed and included in paper format with the assessment letter. Where automatic enrolment assessment notification is provided by email, these documents must be attached to the email. The terms and conditions cannot be provided by linking through to the Aviva (or any other) website from any communication.

Aviva believes that the best way to ensure employees are aware of their enrolment and their right to opt out, is to provide all of the required information in a single communication.

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Step 2 Your automatic enrolment communications continued

Section 1

Qualifying member notice – you will need to issue a qualifying existing member notice to all members of your pension scheme within two months of the start of your auto-enrolment duties. Qualifying existing members are workers already in the pension scheme where employer (and possibly employee) contributions are paid at a level equal to or greater than the automatic enrolment minimum. These workers are mostly unaffected by automatic enrolment, so long as they remain active members in the qualifying automatic enrolment scheme.

Non-qualifying member notice – if a worker is already in the pension scheme but the employer (and possibly employee) contributions are paid at a level less than the automatic enrolment minima required for your scheme, then these workers are required to be assessed for automatic enrolment and enrolled if eligible.

Automatic enrolment notices

You are required to provide the following information about your pension scheme provider in the assessment notices; the details for Aviva are:

Aviva (AE) PO Box 1550 Salisbury SP1 2TW

Tel: 0345 605 4289

Email: [email protected]

Automatic enrolment literature

Prior to your duties start date we will send you an email with links to your automatic enrolment scheme literature. The literature should be issued at the same time as your automatic enrolment notices. You can use the PDFs from the links should you wish to print the literature.

Preparing for opt-out, opt-in and joining instructions

Once your workers receive communication about automatic enrolment they will have the right to opt out, opt in or join. You need to decide how you will process these requests.

You are responsible for informing employees how and when they can opt out, but please be aware you must not issue the opt-out form. That responsibility lies solely with the pension provider. You should inform employees that they should obtain the opt-out form by downloading it from the Aviva website or by contacting Aviva by telephone or email. When Aviva issues the literature items, examples of our opt-out and opt-in/join forms will be included in the email.

Completed opt-out forms should be returned to you so that you can arrange the refund of contributions and stop future contributions before informing us that the member has opted out on the standard spreadsheet. You must stipulate the address for completed forms to be sent to, as these must not be sent to Aviva.

Should an employee wish to opt out after the end of the opt-out period, they cannot do this. However, they can choose to cease active membership by stopping contributions through your normal method, should you allow this.

Aviva will provide your workers with an opt-out form on request if they contact us using the following methods:

Tel: 0345 605 4289

Email: [email protected]

All completed opt-out forms should only be returned to you

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Section 1

8 weeks 4 weeks 2 weeks 1 week Staging Post staging6 weeks2 weeks 1 month 2 months 3 months 4 monthsStaging

Step 3 Creating new members and submitting contributionsNow that all your employees have been assessed for automatic enrolment, you now need to think about creating new member policies and submitting contributions.

Please be aware that you must not submit contributions files and/or contributions for any workers during their opt-out period. Aviva only accepts the first automatic enrolment contributions after the opt-out period has finished. When the opt-out period has passed, before the first contributions can be submitted, you will first need to set up the pension accounts for your automatically enrolled workers on e-serve.

Anyone who has opted out must not have a pension account set up and you will need to refund any deductions taken from these workers.

Loading large number of workers into your pension scheme

There is an e-serve guide which covers the bulk loading of new members which can be found on the ‘User Guide’ menu within e-serve. Alternatively you can access the guide https://library.aviva.com/mpen18a.pdf

If you require training on loading new joiners or paying contributions in bulk, please get in touch with your usual Aviva contact and this can be arranged.

It is important that you do not set up new automatically enrolled workers on e-serve during the opt-out period. Once the opt-out period has expired, you can continue to set these new members up in the normal manner.

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Step 3 Creating new members and submitting contributions continuedSubmitting contributions

Once you have set up the pension accounts for your automatically enrolled workers, you can submit the first contribution(s) for them.

Under the legislation you have an extended time frame to submit the first contributions as shown in the table. The contributions for existing members should continue to be made by the 22nd of the month following deduction as normal.

To help you determine the due date for the payment of the first automatic enrolment contributions, please use the table below by selecting your duties start date and any applicable postponement period.

How do I submit contributions for a salary sacrifice member/scheme?

When members are loaded, we need you to confirm if they are making contributions via salary sacrifice or if they are making personal contributions which will be received as employee contributions alongside your employer contribution. This information determines whether they are set up to receive tax relief on the contributions that are allocated to the member.

If a member is incorrectly set up as a salary sacrifice member, but who should be receiving both employee and employer based contributions, then we will be unable to allocate contributions to the member as the policy may not be aligned.

This could also cause delays in money being allocated to the members’ plans, which could cause financial loss.

Important noteYou are obliged to follow the regulations to fund your workers’ pension to the legal minimum; this legal minimum may change from year to year. Where the legal minimum changes and affects your workers, you will need to arrange an increase in contributions.You are responsible for ensuring that the appropriate automatic enrolment requirements and timings are adhered to.

First automatic enrolment contributions due by the 22nd of the month shown below:Your duties start date

Your postponement period (months)0 1 2 3

1 January April May June July1 February May June July August1 March June July August September1 April July August September October1 May August September October November1 June September October November December1 July October November December January1 August November December January February1 September December January February March1 October January February March April1 November February March April May1 December March April May June

Section 1

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Categories of worker

The diagram below shows the three categories of workers, based on their age and earnings. For example, eligible jobholders are those aged between 22 and State Pension age, who earn more than £10,000 per year.

Section 1

You will need to assess those not in the pension scheme on your automatic enrolment date as being in one of these three categories. Additionally, every pay reference period, you will need to assess those who were non-eligible jobholders or entitled workers on your automatic enrolment date, should they trigger eligibility through a change in age or earnings.

Age from 22 to SPAEarn above £10,000 a year

Eligible jobholder – must be enrolled into the scheme and receive an employer contribution. The employee may also need to pay in.

Entitled worker – has the right to join a scheme. The employer does not have to contribute but may choose to do so.

Non-eligible jobholder – has the right to opt into the scheme and receive an employer contribution. May also need to pay in.

Age from 22 to SPAEarn more than £6,136 but no more than £10,000 or less a year

Age from 16 to 21 or SPA to 74Earn above £6,136 a year

Age from 16 to 74Earn £6,136 or less a year

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Qualifying members: Workers already in the pension scheme where employer (and possibly employee) contributions are paid at a level equal to or greater than the automatic enrolment minima required for your scheme. These workers are mostly unaffected by automatic enrolment, so long as they remain active members in the qualifying automatic enrolment scheme.

Non-qualifying members: Workers already in the pension scheme where employer (and possibly employee) contributions are paid at a level less than the automatic enrolment minimum. These workers are required to be assessed for automatic enrolment and enrolled if eligible.

Contractual joiners: Workers placed into your pension scheme through their contract of employment. Should they be non-eligible jobholders or entitled workers when contractually enrolled and subsequently exercise their cancellation rights, they must be assessed for automatic enrolment every pay reference period and enrolled if they trigger eligibility through a change in age or earnings.

At the time the member meets the conditions to be automatically enrolled, you can choose to use postponement to postpone your duty for up to three months.Category Entitled worker Non-eligible jobholder Eligible jobholder

Are they automatically enrolled?

No No Yes

Can the worker opt in or join? Join Opt in Can opt in if in

postponement

Are employer contributions required?

No Yes, only if the worker opts in Yes

Key:

Section 1

Categories of worker continued

You should also be aware what happens to existing members and those to be placed into the pension scheme through their contract of employment or other written agreement.

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Record keepingAs part of TPR guidance you need to provide Aviva, the pension provider, with jobholder Information within six weeks of the member joining service/becoming eligible, also known as the joining window. The jobholder information to be provided is:

(a) full name

(b) date of birth

(c) postal residential address

(d) gender

(e) automatic enrolment date, automatic re-enrolment date or enrolment date

(f) National Insurance number.

The jobholder information must be kept by Aviva for a minimum of six years in accordance with the legislation.

You also need to provide data on the eligible jobholders or non-eligible jobholders who have submitted valid opt-outs from the scheme. The opt-out data to be provided is:

(a) full name

(b) date of opt-out

The opt-out data must be kept by Aviva for a minimum of four years in accordance with the legislation.

Section 1

Please be aware that Aviva is not required to monitor whether data is being received from employers or to chase up data that has not been received. Aviva is only required to let you know what data needs to be sent to us.

It is important to maintain clear and comprehensive records to ensure your company remains compliant with the automatic enrolment legislation. Aviva is not able to advise you on how to maintain your company records.

As well as supplying information to Aviva, you must keep certain records from your duties start date onwards which The Pensions Regulator may request.

Information regarding record keeping is available on TPR’s website:

www.thepensionsregulator.gov.uk/employers/record-keeping.aspx

and we’ve summarised the key points below.

You must keep the following records:

• information about jobholders and workers;

• records about the pension scheme.

These records need to be kept for six years except for any opt-out data which needs to be kept for four years.

You can use any existing system to collect and keep these records; however, opt-in, joining and opt-out requests must be kept in their original format.

It is possible to outsource the administration of your automatic enrolment scheme to a separate third party and this organisation can be authorised to maintain these records on your behalf.

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8 weeks 4 weeks 2 weeks 1 week Staging Post staging6 weeks2 weeks 1 month 2 months 3 months 4 monthsStaging

Additional informationOngoing assessment

Once you’ve completed the automatic enrolment assessment when your auto-enrolment duties begin or after the agreed postponement period, you will need to continually assess your workers every pay period. Workers will need to be reassessed if they have not already been classed as eligible to see if a change in circumstance, such as age or salary, has altered their assessment status. All new workers will need to be assessed as well.

Cyclical automatic re-enrolment review

In addition, you have a duty to put jobholders back into pension saving on a cyclical three-year basis. The process of automatic re-enrolment is the same as automatic enrolment.

There are key points that you need to be aware of regarding re-enrolment:

• Automatic re-enrolment applies to eligible jobholders who have already had an automatic enrolment date with you.

• Postponement cannot be used with automatic re-enrolment. If the criteria are met on the automatic re-enrolment date, then the jobholder must be automatically re-enrolled from that date.

• You do not have to assess all your workers – just those who have opted out or ceased membership of a qualifying scheme.

• The assessment process for automatic re-enrolment is separate to your usual assessment in each payment reference period and is run approximately every three years.

• The revised contribution levels following automatic re-enrolment are only applicable after the opt-out period.

• Members who are re-enrolled and are not happy with the revised contribution levels should adjust the contribution amounts by speaking to their employer (not just to opt out).

• Members who are re-enrolled and who opt out, will cease membership for the scheme.

You will need to choose your automatic re-enrolment date from within a six-month window, starting three months before the third anniversary of your original duties start date and ending three months after.

The date chosen is at employer level; different dates cannot be chosen for different categories of worker.

As postponement is not available, you may wish to choose a date that coincides with the first day of a pay reference period to avoid partial contributions.

Re-enrolling members

You can add re-enrolled members to your scheme by submitting a bulk load of re-enrolled members in exactly the same way as you do for automatic enrolment. The data required and the process on e-serve is the same.

Please be aware that with re-enrolment, as automatic enrolment, you must not submit contributions files and/or contributions for any workers during their opt out period. Aviva only accept the first contributions in respect of automatic enrolment and re-enrolment after the opt out period has finished. When the opt out period has passed, before the first contributions can be submitted, you will first need to set up the pension accounts for your automatically enrolled and re-enrolled workers on e-serve.

Further information on cyclical automatic re-enrolment can be found on the Pensions Regulator’s website: www.thepensionsregulator.gov.uk/docs/detailed-guidance-11.pdf

Section 1

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Additional information continuedDeclaration of Compliance – registering your scheme with The Pensions Regulator

You must complete a declaration of compliance (registration) with TPR up to five calendar months from your duties start date at www.thepensionsregulator.gov.uk/employers/automatic-enrolment-registration.aspx.

You will need certain pieces of information to complete the registration. Please click here to view the full registration checklist. To help you complete the information required about the pension scheme, please see the guidance below:

• Type of pension scheme(s) used for automatic enrolment (personal or occupational): This can be found on the Scheme summary page of e-serve.

• Employer pension scheme reference (EPSR): This is the scheme reference number, prefixed with an ‘F’ and followed by five numbers which identifies your scheme (for example, F12345).

• Pension scheme registry number (PSR): This is only required for occupational schemes. If you have a group personal pension scheme or group stakeholder pension scheme, this is not applicable.

• Name and address of the pension scheme(s) used for automatic enrolment: This is your pension scheme name, followed by our Dorking address which is:

Aviva Pixham End Dorking Surrey RH4 1QA

Re-declaration of Compliance

In a similar way to cyclical automatic re-enrolment, you will need to complete a re-declaration of compliance approximately every three years.

You have until the day before the third anniversary of your last declaration to re-declare compliance. However, if you have workers who need to be re-enrolled when you assess them at your cyclical automatic re-enrolment date you must complete your re-declaration of compliance at the same time – you cannot wait until the third anniversary of your last declaration if this is later.

Section 1

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What do you need to do to get ready for automatic enrolment?

You should know your duties start date and read the employer leaflets on TPR’s website, as well as Aviva’s guides. You should also analyse your workforce and estimate the costs of automatic enrolment, which will vary depending on the contribution strategy (e.g. minimum or existing contribution profile).

What are the penalties for non compliance?

TPR has the ability to impose penalty notices if you do not comply with your new duties. These include:

• Escalating penalty notices if you have sought financial gain through avoiding your obligations. Fines range from £50 to £10,000 a day depending on the size of your company.

• Fixed penalty notices of £400 if you fail to respond to a warning from TPR.

• Prohibited recruitment conduct penalty notices, if you are charged with screening job applicants for their intention to join the pension scheme. Fines can be up to £5,000 a day depending on the size of your company.

If a scheme has a probation period before allowing workers to join the scheme, is this affected by automatic enrolment?

Employers have the option of postponing the assessment of workers for a period of up to three months where they are using the National Employment Savings Trust (NEST), defined contribution (DC) or defined benefit (DB) schemes. Employers who are using a DB scheme may be able to postpone for a longer period and should contact their adviser if they are interested in this.

All jobholders will have the ability to opt into the pension scheme during this postponement period and unless they are an entitled worker (earning £6,136 or less a year), they will be eligible to receive an employer contribution.

Will automatically enrolled workers be able to choose their own investment funds?

Yes. A default investment solution must be in place. However, members will be able to choose from the range of funds offered by the scheme should they not wish to remain in the default.

How do members opt out?

The worker must return their completed opt-out form in order for the employer to opt them out of the scheme.

Information regarding this process should be included in the assessment notice issued to the worker. The opt-out form can only be issued by the pension scheme provider and not the employer.

Further information on what happens if you don’t comply can be found on The Pensions Regulator’s website:www.thepensionsregulator.gov.uk

Section 2 Frequently asked questions

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EPEN22/C NG08085 04/2019

Aviva Life & Pensions UK Limited. Registered in England No. 3253947. Registered office: Aviva, Wellington Row, York, YO90 1WR. Authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Firm Reference Number 185896.Telephone 0345 602 9189 – calls may be recorded. www.aviva.co.uk

This guide is subject to change by Aviva. When this happens, Aviva shall make updated versions available to employers and/or trustees.

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