These included enrolling staff into a scheme from their staging date, paying contributions, writing to staff explaining how automatic enrolment affected them, and completing a declaration notice to indicate the company had complied with its duties.
According to a TPR report published today, a notice was issued on 18 August directing the club to automatically enrol staff and pay contributions. However, TPR claimed the company failed to act by the deadline of 17 October 2014 and the declaration remained incomplete. It then issued a fine of £400 which the employer did not pay.
An escalating penalty notice was issued on 20 January 2015, warning the employer that if it did not comply within 28 days, it would be fined at the rate of £2,500 per day.
The football club initially contacted TPR but compliance and declaration were still unsatisfactory, said the regulator. Therefore the fine of £2,500 a day started to accrue from 18 February 2015.
The penalty was stopped on 26 February once STFC had completed a declaration of compliance, provided supporting evidence and assured the regulator that backdated contributions would be paid within two weeks.
However, on 23 March 2015, TPR received a report from the firm's pension provider confirming no contributions had been made, including back payments owed.
Meanwhile, STFC also requested a review of the escalating penalty notice. In response to the request, TPR asked the club to get in touch 'urgently' to discuss the outstanding pension contributions.
With no payments forthcoming, on 12 June 2015 another notice was issued requiring the firm to act within 28 days. The regulator received no response. As a result they conducted an inspection on STFC, during which the company agreed to take specific action to fulfil its duties.
TPR argued despite initial progress, contributions were still outstanding, so they issued a second escalating penalty notice on 17 December 2015 requiring the missing contributions to be made by 28 January 2016.
The pension provider confirmed on 18 January 2016 that the contributions had been paid up so no penalty was accrued.
Outstanding contributions stood at £13,613.39. Payments for all the back contributions up to December 2015 were made in three instalments between 15 and 19 January 2016.
The penalty of £22,900, which included the initial fine of £400, was settled on 16 February 2016.
The regulator said the case highlighted the need to engage early and the club's initial lack of action led to further delays in complying with their duties.
Charles Counsell, TPR's executive director of automatic enrolment, said: "This case illustrates what can happen when an employer buries their head in the sand and disregards their duties."
STFC could not be reached for a comment.