Frequently asked questions about Contribution Monitoring
If you're looking for more information about the changes being made to how we monitor contributions, our Frequently Asked Questions may have the answer you're looking for.
Changes do not need to be made to how you calculate pensionable earnings, we simply require you to add the earnings figure to the contribution file.
Why is Contribution Monitoring changing?
Why does Royal London require additional information and why is this a new requirement?
The Pensions Regulator (TPR) has instructed pension providers – like Royal London – to ensure their processes for monitoring contribution compliance is reviewed and updated to reflect their focus on driving good member outcomes. Royal London requires the additional information to ensure we can meet our duty to monitor the payment of contributions into the scheme and identify underpayments or overpayments as well as non-payments.
What is Royal London monitoring and how are you doing this?
Royal London will be monitoring the contribution amounts submitted by employers, and checking if these match the contribution amounts Royal London expect. This is based on the contribution rates Royal London hold and the pensionable “earnings in the current contribution period” the employer includes in the contribution submission.
What schemes and products are affected by TPR’s changes?
All occupational and contract-based workplace pension schemes are affected by these changes, with an initial focus on schemes that submit their contributions online via our Automatic Enrolment Dashboard.
We use an independent auditor to audit contributions. Do we still need to provide this additional information?
Yes – this is a minimum required standard and TPR expect Royal London to fulfil our monitoring responsibilities.
Will an employer be reported and/or fined by TPR?
We have a duty to report any employers that fail to comply with the requirements to TPR. At this point, it's TPR's decision whether to impose any fines on the employer.
What will I have to do differently?
Will there be a new contribution template?
If you already provide pensionable earnings in your existing contribution template then no change will be required. If you don't, you'll need to update your template to include this information accordingly.
- Example of RGP and SHR scheme contribution template can be downloaded here (XLSX)
- Example of CMP scheme contribution template can be downloaded here (XLSX).
The example contribution templates correspond with the prefix of your scheme number which can be located at the top right corner of Dashboard or via our online services.
Can I get my files ready in advance of May 2024?
Yes, you can start updating your files and providing pensionable earnings for your workers to us, any time before May 2024 and we'd recommend that you don't wait until May 2024 to start providing this information.
How do I map my new contribution template to Dashboard?
It is done the exact same way as you would normally do it now, there's no change to this process.
More information on this process can be found here (PDF) (opens in new window).
Can I still input the contribution amounts to the Dashboard manually?
Yes provided you input the workers' pensionable earnings in the 'Earnings in contribution period' field when submitting your contribution manually.
What if there’s an error?
How will errors be flagged with employers?
The contribution monitoring process will run alongside the normal contribution submission process. If contributions submitted are different from what Royal London expect based on the information the employer has provided to Royal London, a contribution mismatch will be flagged to the employer. The employer can review/update the details they’ve entered on the schedule if an error has been made; or will be asked to pick a reason from a dropdown list if there is a genuine mismatch.
How long does an employer have to correct any errors?
Employers will need to either review and update the pensionable earnings and or contribution amounts they are submitting or select a reason for any genuine mismatches before they can submit the contribution schedule.
What happens if I don’t make changes?
Will an employer be reportable if the member contributions are restricted by Money Purchase Annual Allowance (MPAA) or Tapered Annual Allowance?
No, this is a valid reason for underpaying and Royal London are not required to report these instances.
How will you report an employer to TPR?
We currently use an online portal for reporting non-payments. We'll work with TPR to agree the approach for reporting on contribution monitoring.
What are the implications if an employer is unable to supply the required information?
If an employer is unable to supply the required information as part of their monthly contribution schedule, they'll not be able to submit their schedule. This can result in the employer being reported to TPR for missed contributions.
What do I do if?
What figure do I need to provide in the Earnings in Contribution period?
If the definition of pensionable pay is qualifying earnings, you’ll need to exclude earnings below the lower earnings limit, and where relevant not include any earnings above the upper earnings limit.
I have a member that pays a fixed sum each month, what should be included as pensionable earnings on the file?
For members that have a fixed contribution/sum paid for them each month, the validation check will be on the fixed amount paid compared to the fixed amount we are expecting. However, we would still expect if they had earnings in the contribution period, that's entered.
Where a member is on maternity/parental leave, what earnings figure are you looking for?
There is one field for earnings in current contribution period so we cannot capture two different earnings. You should include actual pensionable earnings. If a payment mismatch validation occurs, there is a Maternity/Paternity Leave dropdown reason to let us know this is the reason why.
The definition of pensionable salary in payroll does not match the definition of pensionable salary of the Royal London scheme?
Contact your Servicing Team.
A worker is looking to temporarily increase / decrease their contribution rate – do I have to inform Royal London?
If it is a temporary increase/decrease, then you do not need to contact us.
Dashboard won’t accept my contribution file as the template headings don’t match
If you have amended the headings of your contribution template then you will require to create a new template. The process to do this is outlined within the attached user guide (PDF) (opens in new window) and following templates:
- CMP scheme contribution template (.XLSX)
- RGP/SHR contribution template (.XLSX).
How do I?
How do I delete templates that I no longer require if I now have multiple contribution templates on the Dashboard?
Call or email your Servicing Team via the contact us link on the top right of the Automatic Enrolment Dashboard and we can delete them for you.
How do I find the contact details of my Corporate Servicing Team?
There is a link called Contact Us in the top right-hand corner of the Automatic Enrolment Dashboard.
How do I inform Royal London if a worker currently pays a fixed contribution amount as opposed to a %?
Click on the link in the top right-hand corner of the Automatic Enrolment Dashboard which says contact us and fill in the form.
How do I inform Royal London if a worker has started / ceased using Salary exchange?
Click on the link in the top right-hand corner of the Automatic Enrolment Dashboard which says contact us and fill in the form.
How do I check what contribution rates and / or salary information Royal London currently hold for workers?
You can check the information we hold by requesting a bulk data extract from your Corporate Servicing Team.
How do I update a contribution rate that Royal London hold for a worker?
You can do this one of two ways, either contact your Corporate Service team via 'contact us' at the top right of Automatic Enrolment Dashboard or you can chose the member from our online service and then select change details.
Salary exchange
What is salary exchange and is it different to salary sacrifice?
Salary exchange is sometimes referred to as salary sacrifice. Put simply, it's an agreement between you and your employees, where they agree to exchange part of their gross salary, bonus or even redundancy package for a pension contribution. It works in a similar way as other salary related benefit schemes, for example company car, cycle to work and childcare voucher schemes.
What checks were previously being done on salary exchange contributions and what will happen after these enhancements are introduced to the Dashboard?
For worker's using salary exchange the Dashboard checks that the contribution was being received as an employer only contribution and produce a validation if a worker contribution amount was listed in the upload.
The validation checks are being enhanced and once delivered Dashboard will also validate that the salary exchange contribution amount received is in line with the contribution amount that we are expecting. If this differs you will be asked to provide a reason as to why.
What earnings figure should be provided if using salary exchange for pension contributions?
The earnings figure we will require to be input is the worker's pensionable earnings figure that the pension contribution % has been calculated from. The Dashboard will take the pensionable earnings figure provided and apply the contribution % held on our records to calculate the contribution amount we are expecting to receive.
What earnings figure should be provided if using salary exchange for other deductions as well as the pension contributions?
The earnings figure we will require to be input is the worker's pensionable earnings figure that the pension contribution % has been calculated from. If a salary exchange agreement is written in a way that a worker's:
- Pension contribution is calculated based on the pensionable pay prior to any other salary exchange deductions then we require the pensionable earnings figure pre other salary exchange deductions.
- Pensionable pay is reduced because of other salary exchange deductions and as a result their pension contribution reduces then we would require the pensionable earnings figure after the other salary exchange deductions.
The Dashboard will take the pensionable earnings figure provided then apply the contribution %'s we have on our records to calculate the contribution amount that we would ordinarily expect.
How can I check whether the pension scheme is set up to use salary exchange?
Contact your Servicing Team, their contact details can be located by selecting 'contact us' at the top right corner of Dashboard.
How can I check whether the pension scheme is set up to reinvest any employer and / or employee savings as a result of salary exchange?
Contact your Servicing Team, their contact details can be located by selecting 'contact us' at the top right corner of Dashboard.
How can I amend how salary exchange is set up on the scheme eg switch off National Insurance reinvestment?
Contact your Servicing Team, their contact details can be located by selecting 'contact us' at the top right corner of Dashboard. You may also require to review and / or update the salary exchange agreements you have in place and you should seek your own advice in this regard.
I am about to start deducting contributions via salary exchange however the pension scheme is not set up to accept it – how do I update it?
Contact your Servicing Team, their contact details can be located by selecting 'contact us' at the top right corner of Dashboard.
Before setting up a salary exchange arrangement, it's important to make sure you've got everything in place that's needed. This includes making amends to employees' contracts of employment so they meet legal requirements. As this is a matter of employment law, you should speak to your legal advisers.
How should a salary exchange contribution be submitted to the Royal London Dashboard?
Any contribution deducted via salary exchange should be combined with the employer contribution amount when submitting a contribution to Dashboard to avoid the worker erroneously receiving duplicate tax relief.
I have an employee that has agreed to salary exchange their bonus / redundancy payment, how should this be submitted to Royal London?
You should combine the exchanged bonus / redundancy payment with the worker's monthly contribution upload as an increased employer contribution amount. You will receive a mismatch validation upon submission where you can select the appropriate reason for the mismatch.
I don’t currently use salary exchange but would like to introduce it to the workforce for the pension contributions, where can I find additional information?
Additional information about salary exchange can be found in the following guides:
- An employer guide to introducing salary exchange (PDF) (opens in new window): This explains how salary exchange works and includes examples of the benefits and savings at employer and employee level.
- An employer guide to setting up salary exchange (PDF) (opens in new window): Detailing key considerations for employers when setting up their salary exchange arrangement.
Others
Will Royal London cover any costs for changes to payroll?
No – as this is a minimum standard requirement set out by TPR, all employers are required to provide this information to their pension provider.
What is meant by pensionable earnings?
The information we require is a worker's pensionable earnings for the relevant contribution period. This should be the earnings that you've used to calculate the pension contribution based on your scheme's definition of pensionable pay. If the definition of pensionable pay is qualifying earnings, you'll need to exclude earnings below the lower earnings limit, and where relevant not include any earnings above the upper earnings limit. If using salary exchange for pension contributions, you'll need to provide us with the worker's pre salary exchange pensionable earnings.