Auto-enrolment for agency temps: who enrols them, when hours cross the trigger and how postponement works

Temps are the part of an agency's payroll where workplace pension duties go wrong most often. The hours change from week to week, assignments end before anyone has thought about pensions, and some owners assume the client deals with it. This guide sets out who the employer is for pension purposes, what the 2026/27 thresholds mean in hours, and how to use postponement properly.

Who has to enrol the temp

For automatic enrolment, the Pensions Regulator's guidance says an agency worker's employer is whichever of the agency or the hirer "is responsible for paying the worker under any arrangement between the agent and the principal". If the contract between you and the client does not say, it is whichever party actually pays.

For most employment businesses that means you. You run the payroll, so you assess the temp, enrol them, collect and pay contributions and send the letters. The client does not pick this up because the temp works on its premises. The same applies where you engage temps on a contract of employment with you: you are the employer in any case.

If an umbrella company pays the worker, the umbrella holds the duty. That is one reason to check how umbrellas on your list handle pensions, alongside the tax points in our guide to IR35 and umbrella liability.

The 2026/27 thresholds in hours

The Pensions Regulator has confirmed the thresholds for the tax year from 6 April 2026 are unchanged:

You assess against the figure for your pay period, so a weekly payroll uses the weekly column. At the National Living Wage of £12.71 an hour, we worked out where those lines fall:

So the trigger sits at 15.11 hours a week at the minimum rate, and the lower limit at 9.44 hours. A temp on a higher rate crosses both sooner. Workers aged 16 to 21, or from state pension age to 74, are never enrolled automatically, but they can ask to opt in or join.

What each category means for you:

• Eligible jobholder: you must enrol them and pay contributions.
• Non-eligible jobholder: you do not enrol them, but if they opt in you must enrol them and pay employer contributions.
• Entitled worker: they can ask to join a pension scheme. You must arrange it, but you do not have to contribute.

Why one busy week matters

The assessment is not done once. Where a temp is not an eligible jobholder, the guidance makes the first day of each later pay reference period a new assessment date. A temp who has worked 12-hour weeks for two months and then picks up a 20-hour week becomes an eligible jobholder in that week, unless you have postponed.

Postponement, used properly

Postponement lets you delay assessment for up to three months from a worker's first day, or from the day they first become eligible. The guidance names short-term workers and those "with rare spikes in earnings" as cases it suits. For a temp desk it covers most short bookings: a six-week assignment can end inside the postponement period, and there is nothing to enrol.

Three conditions come with it:

1. Notice in time. You must give the worker a postponement notice no later than six weeks and a day after the start of the postponement. Postponing in your payroll software without sending the notice does not count.
2. The worker can still opt in. The notice must tell them they can ask to be enrolled during the postponement, and if they ask you must do it.
3. No second go. If the worker is an eligible jobholder on the deferral date, you must enrol them then. You cannot postpone that worker again. Postponement is also not available at re-enrolment.

What enrolment costs on a full-time temp

For a temp on 37.5 hours at £12.71, qualifying earnings are £476.63 minus £120, which is £356.63 a week. The minimum total contribution is 8% of that, £28.53, with at least 3% from the agency (£10.70) and the rest from the worker. Our temp margin calculator builds the employer share into the hourly cost, and the Key Information Document template has a line for showing pension deductions to the worker.

A check to run on this week's payroll

1. Confirm your terms with each client say the agency pays the temp, so there is no doubt who holds the duty.
2. For every temp who started in the last six weeks, check a postponement notice went out, or that they were assessed.
3. List temps whose pay crossed £192 this week for the first time and check whether they are postponed.
4. List temps whose postponement ends this month and assess them on the deferral date.
5. Make sure any temp who asked to opt in or join has been dealt with.

Overlyft can set up an AI assistant to prepare that list from your timesheets, flag temps about to cross £192 or reach a deferral date, and draft the notices for you to check and send. Enrolment decisions, and what goes to the pension scheme, stay with you and your payroll provider. This page is general information, not legal or pensions advice.