PPE remains in play?
The bill foresees an option whereby employers who run an employee pension program (PPE, Pracowniczy Program Emerytalny) do not have to establish the PPK, provided that:
- the employer’s basic contribution is at least 3.5% of the remuneration;
- the participation level in the PPE is at least 25% of all the persons employed (not just employees, but all the persons who can participate in the PPK);
- the PPE will have been launched prior to the date when the PPK Act applies to the given employer. Thus, for entities employing at least 250 persons such a program should be launched before 1 July 2019.
When making the decision on the establishment of the PPE, you should take into consideration the time it takes for the Financial Supervision Authority to register such programs, which is about 2-3 months at present. Moreover, the registration of the program is not everything – it is also necessary to reach the required participation threshold and to pay the initial contributions. All this has to happen before the deadline in question.
Thus, in the case of entities employing at least 250 persons, the decision to establish a PPE should, for all practical purposes, be taken now. Until the plant-level PPE agreement has been concluded, the employer has the option to unilaterally withdraw from the project, if for some reason it decides that the PPE is not the best option for it.