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Seasonal Staff Warning from HMRC

Updated on October 18, 2026

Last updated: 16 October 2026

Do seasonal staff need to be auto-enrolled into a pension?

Yes. Seasonal and temporary workers have the same workplace pension rights as permanent staff. HMRC and The Pensions Regulator regularly remind employers in retail, hospitality, farming and events that taking on extra hands for a busy period does not remove auto-enrolment duties. You must assess every worker each time you pay them.

Who must be enrolled?

Worker type Age Earnings in the pay period What you must do
Eligible jobholder 22 to State Pension age Over £10,000 a year (£833 a month, £192 a week) Enrol automatically and pay contributions
Non-eligible jobholder 16 to 74 Between £6,240 and £10,000 a year, or aged 16 to 21 or SPA to 74 earning over £10,000 Enrol if they ask, and pay employer contributions
Entitled worker 16 to 74 £6,240 a year or less Let them join if they ask; no employer contribution required

These thresholds stayed the same for 2026/27. The weekly and monthly figures apply to each pay period, so a seasonal worker paid weekly who earns over £192 in a week must be enrolled that week unless you postpone.

Using postponement

You can postpone assessment for up to three months from a worker’s start date. This is useful for short contracts: if the job ends before the postponement period, you may never need to enrol them. You must write to the worker within six weeks of their start date to tell them about the postponement, and they can still choose to join.

Contributions

The minimum total contribution is 8% of qualifying earnings, at least 3% of which must come from the employer. Qualifying earnings are pay between £6,240 and £50,270 a year, worked out pro rata for each pay period. The DWP’s review of the thresholds confirmed that these figures, and the £10,000 earnings trigger, stay the same for 2026/27.

Example

A seaside café hires a student, aged 23, for 10 weeks over summer, paying £450 a week. Her earnings are above £192 a week, so she is an eligible jobholder. The café can postpone for up to three months and her job ends before then, so she does not have to be enrolled unless she asks to join. If the café does not postpone, it must enrol her and pay 3% of her earnings above £120 a week (£9.90 a week).

Penalties for getting it wrong

The Pensions Regulator can issue a fixed penalty of £400, followed by escalating daily penalties of £50 to £10,000 depending on the number of staff. You must also re-declare compliance every three years.

Payroll tips for seasonal staff

  1. Set up auto-enrolment assessment in payroll for every pay run.

2. Send postponement letters on time.

3. Keep records of opt-outs; refunds are due if staff opt out within a month.

4. Remember the National Living Wage is £12.71 an hour for workers aged 21 and over from April 2026.

Frequently asked questions

Can a worker opt out?

Yes, after being enrolled. You cannot encourage them to do so.

Do agency workers count?

The agency that pays them usually has the duties.

What if a seasonal worker returns next year?

Assess them again when they restart.

Do directors need enrolling?

Not if they have no employment contract, or if they are the only employee.

Related: pension rules for seasonal employees, payroll hygiene and minimum wage rules.

Talk to Accotax

Want this handled for you? Our team at Accotax can help with auto-enrolment for seasonal staff. See our payroll services service, or contact us for a free, no-obligation quote.

This page is general guidance based on HMRC rules for the 2026/27 tax year, checked against gov.uk on 16 October 2026. It is not personal advice, so speak to an accountant about your own situation.

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