Key takeaway: Every employer must re-enrol eligible workers who previously opted out of auto-enrolment every three years, on or around the anniversary of their staging date or duties start date. Employers who first auto-enrolled in 2023 are now due their first re-enrolment cycle. For payroll bureaus managing employer clients, identifying which clients are due for re-enrolment in 2026, running the assessment correctly, and completing the re-declaration of compliance with The Pensions Regulator are all tasks that need to be on the bureau’s radar — and BrightPay is built to manage every stage of the process.
Auto-enrolment re-enrolment is one of the most frequently missed employer compliance obligations. Unlike the initial auto-enrolment, which was a high-profile one-time event for most employers, re-enrolment is a recurring obligation that arrives quietly every three years with no external prompt unless the bureau or practice has a process to identify it. The Pensions Regulator does not send automatic reminders. Employers who miss their re-enrolment window face compliance notices and, in persistent cases, fines.
For payroll bureaus managing large numbers of employer clients, re-enrolment is a workflow management challenge as much as a technical one. The three-year cycle means that in any given year, a proportion of the client base will be due for re-enrolment — and identifying which clients, assessing which workers are eligible, and completing the process within the correct window requires systematic tracking, not manual memory.
What Re-Enrolment Requires
Re-enrolment must be completed within a six-month window centred on the third anniversary of the employer’s staging date or duties start date (the three-month period before and the three-month period after the anniversary date).
Within that window, the employer must:
Assess the workforce. Re-enrolment applies to workers who were previously auto-enrolled and then opted out, or who had their contributions reduced below the minimum level. Workers who are currently active members of the qualifying workplace pension scheme do not need to be re-enrolled — only those who opted out or ceased active membership.
Re-enrol eligible workers. Workers who meet the eligibility criteria — broadly, aged between 22 and state pension age, earning above the earnings trigger (£10,000 per year in 2026/27), and not currently an active member of the qualifying scheme — must be re-enrolled. The employer must write to each re-enrolled worker within six weeks of re-enrolment, explaining what has happened and that they have the right to opt out again if they choose.
Complete the re-declaration of compliance. Within five months of the re-enrolment anniversary date, the employer must submit a re-declaration of compliance to The Pensions Regulator via its online portal, confirming that re-enrolment has been completed. Failing to submit the re-declaration is itself a compliance breach, even if the re-enrolment process was completed correctly.
Workers who are re-enrolled have the right to opt out again within one month of being re-enrolled. If they opt out within this window, any contributions deducted must be refunded. After the one-month window, the opt-out cannot be applied retroactively.
Who Is Due for Re-Enrolment in 2026
Employers who staged or started their auto-enrolment duties in 2023 are due their first re-enrolment in 2026. Given that staging dates for smaller employers were largely from 2016–2018, many employers will be completing their third or fourth re-enrolment cycle. For newer employers whose duties start date was 2023, 2026 is the first time they will have experienced the re-enrolment process.
For payroll bureaus, the relevant question is: which of my clients have a three-year anniversary falling in 2026? Without a system that tracks re-enrolment dates, the answer requires manually checking each client’s staging or duties start date — a significant administrative burden across a large bureau portfolio.
The Minimum Contribution Rates for 2026/27
Re-enrolled workers are enrolled into the qualifying workplace pension scheme at the minimum contribution rates. For 2026/27, total minimum contributions remain at 8% of qualifying earnings, with a minimum employer contribution of 3% and a minimum total contribution of 8% (with the employee making up the difference). There have been no changes to contribution rates in 2026, so re-enrolled workers’ ongoing contributions follow the same structure as currently enrolled workers.
One area worth checking for all employer clients, not just those going through re-enrolment: salary sacrifice arrangements can affect qualifying earnings calculations. Ensuring that the pension contribution basis — whether salary sacrifice or relief at source — is correctly applied in the payroll system prevents errors that can generate compliance queries from pension providers.
How BrightPay Manages the Re-Enrolment Process
BrightPay is designed to manage the full auto-enrolment lifecycle, including re-enrolment. For each employer client managed through BrightPay, the system tracks the staging date or duties start date and identifies when the three-year re-enrolment window is approaching. This removes the need for bureaus to manually track re-enrolment dates across their client base.
When the re-enrolment window opens, BrightPay runs the workforce assessment automatically — identifying workers who opted out and assessing their current eligibility against the age and earnings criteria. Eligible workers are flagged for re-enrolment and the process is managed within BrightPay‘s auto-enrolment workflow, including the generation of the required worker communications.
The re-declaration of compliance is supported within BrightPay‘s auto-enrolment module, which provides the information needed to complete the Pensions Regulator submission and confirms that all required steps have been completed.
For bureaus managing multiple employer clients with re-enrolment due in the same period, BrightPay‘s visibility across all clients in the bureau’s portfolio allows the work to be planned and managed efficiently — rather than responding reactively to clients who have missed their window.
Practical Checklist for Bureau Clients Approaching Re-Enrolment
For each employer client due for re-enrolment in 2026:
- Confirm the re-enrolment window dates (three months either side of the third anniversary of the staging or duties start date).
- Run the workforce assessment to identify workers who opted out or ceased active membership and are now eligible for re-enrolment.
- Notify the pension scheme provider of the re-enrolled workers.
- Generate and send the required written communication to re-enrolled workers within six weeks of re-enrolment.
- Process the first contributions for re-enrolled workers in the correct payroll run.
- Submit the re-declaration of compliance to The Pensions Regulator within five months of the re-enrolment anniversary date.
- Process any opt-out requests received within the one-month window and refund contributions where required.
Frequently Asked Questions
What is auto-enrolment re-enrolment and why must employers do it?
Re-enrolment is the legal requirement for employers to reassess workers who previously opted out of auto-enrolment and re-enrol those who now meet the eligibility criteria, every three years. The requirement exists because workers’ circumstances change — someone who opted out three years ago may now benefit from being enrolled. Employers who fail to re-enrol eligible workers or submit the re-declaration of compliance face enforcement action from The Pensions Regulator.
How often must employers carry out re-enrolment?
Re-enrolment must be completed every three years, within a six-month window centred on the anniversary of the employer’s original staging date or duties start date.
Which workers must be re-enrolled?
Workers who previously opted out of the qualifying workplace pension scheme and who currently meet the eligibility criteria must be re-enrolled. The eligibility criteria are: aged between 22 and state pension age; earnings above the earnings trigger (£10,000 per year in 2026/27); and not currently an active member of a qualifying scheme. Workers already enrolled do not need to be re-enrolled.
Can workers opt out again after re-enrolment?
Yes. Re-enrolled workers have a one-month window from the date of re-enrolment to opt out. If they opt out within this window, any contributions deducted must be refunded. After the one-month window, the opt-out cannot be applied with retroactive effect, and the worker remains enrolled until they make a separate cessation request.
What is the re-declaration of compliance and when must it be submitted?
The re-declaration of compliance is a submission to The Pensions Regulator confirming that the employer has completed re-enrolment. It must be submitted within five months of the re-enrolment anniversary date through the Pensions Regulator’s online portal. Failure to submit is a separate compliance breach from any failure in the re-enrolment process itself.
BrightPay tracks re-enrolment dates for every employer client, runs the workforce assessment automatically when the window opens, and manages the re-enrolment communications and process within the payroll workflow — so bureaus never miss a client’s three-year cycle. Find out more about BrightPay or speak to your account manager.
