Too soon to be thinking about Christmas?  Possibly not.

The requirements of the Pensions Act 2008 impose positive obligations on almost all employers, requiring them to have in place a qualifying workplace pension arrangement and to automatically enrol employees into it (subject to various conditions).  The obligations extend to deducting and paying across required employee contributions and to paying employer contributions.

The obligations apply to each employer from its 'staging date', which is specific to the employer in question.  The timing of staging dates means that there was to be a significant increase in their number in July.  However, feedback from a range of pension advisers is that there has not been the increase in activity that one would have expected from those employers. Many employers may be taking advantage of a provision allowing postponement of implementation for up to three months, but the general understanding is that a good number are simply doing nothing.

This is something of concern and will likely increase in scale as smaller employers reach their staging dates.  Those concerns are shared by The Pensions Regulator, with its executive director for automatic enrolment commenting that many employers still do not know their staging dates.

Implementing auto-enrolment need not be difficult, with proper advice, but may require employers to record small but important changes in their terms and conditions of employment.

Failing to comply with the requirements can result in a range of financial penalties: in the worst cases, up to £10,000 per day, if there is an ongoing failure.

The Regulator will know whether employers have done what is required of them, because one of the employer obligations is to confirm to it that they have done so (by submitting an online certificate within five months of its staging date).

With that in mind, for employers with a July staging date (employers with at least 62 employees), amongst their festive cards and greetings, they may also get a letter from the Regulator querying what, if any, action they have taken on auto-enrolment.

So, if you are an employer, on which list will you be – naughty or nice?  It is worth checking, perhaps even twice.