Can an employer postpone its pensions auto-enrolment duties on multiple occasions in relation to the same worker?

Postponement allows an employer to delay its duty to auto-enrol eligible jobholders for up to three months. The employer can apply postponement:

  • from the date on which its auto-enrolment duties start;
  • to new workers on starting employment; and/or
  • when someone becomes an eligible jobholder.

The employer can use postponement again, the next time that its auto-enrolment duties are triggered in relation to a worker, as long as they are not an eligible jobholder on the deferral date (the last day of the postponement window). For example, an employer applies a three-month postponement period, with a deferral date of 31 December, to a worker because a period of overtime in October took their qualifying earnings over the earnings threshold, triggering auto-enrolment. On 31 December, the employer reassesses the worker, who has not been paid for any overtime in December; qualifying earnings do not exceed the monthly qualifying earnings threshold so they are not an eligible jobholder. The worker is paid a bonus in January, which again triggers auto-enrolment. The employer can apply postponement again for up to three months. There is no limit to the number of times that an employer can apply postponement.