Pensions dashboards will bring about a landmark change in the way individuals can access information about their pensions. For the first time, savers will be able to see most of their future pension information securely online, and all in one place helping to support retirement planning.
Although pensions dashboards have been a long time coming, there was significant progress made over 2022 and the early part of 2023 with the outcome of formal consultations and draft regulations being published, putting much needed flesh on the bones of how pension dashboards will work and helping both trustees and administrators know what they need to do to ensure compliance.
Whilst on the 3rd of March, pensions minister Laura Trott published a written statement saying the timetable for the launch of Pensions Dashboards was being “reset” there is still progress that schemes need to continue to make to ensure they are well placed to be able to connect to Pensions Dashboards and provide the information that will be expected by the public.
At the beginning of June 2023 laid the Pensions Dashboards (Amendment) Regulations 2023, a link to a summary of the regulations can be found here and a link to the full amended regulations can be found on TPR’s ‘Stay in touch with developments’ page. The key points to note are a DWP final connection date announced as 31 October 2026, Staging dates for schemes will be published in guidance to be consulted on later this year and the Dashboard available Point (DAP) for consumers may be ahead of the final connection date.
We await the DWP connection guidance provided for in legislation which should confirm staging dates for schemes leading up to the October 2026 final connection deadline announced.
How can we help?
We are already advising our largest schemes on the steps to connection and have been preparing to connect to Dashboard ourselves for all the pension schemes we administer so are well placed to help you navigate your path to connection. We are also taking the necessary steps as a scheme administrator to ensure connection to pensions dashboards.
There are many questions that our clients are asking of us such as:
From the work undertaken with clients whose original staging date was August 2023, we have a wealth of experience already of Pensions Dashboards and would be delighted to talk to you with a view to supporting you with what is required to comply.
As well as working with our clients we have also been liaising industry wide with those directly involved in the development of draft regulations and using our connections with PASA. We hosted our first fireside chat to bring to life all things Pensions Dashboard late last year. In June 2023 we have a further fireside chat involving several industry experts to discuss the impact of the reset and confirm what schemes should still be continuing to do interim to ensure they remain ready for compliance. Further details can be found below.
In this publication, Laura McLaren, Karl Lidgley and Stuart Reid provide a simple guide to pensions dashboards and the steps you can take now to prepare.
The government estimates that on average, people may build up 11 different pension pots in their lifetime, and it can be difficult to keep track of them all.
Pensions dashboards is anticipated to 'revolutionise' the way people interact with their pensions by allowing individuals to see all of their pension’s information, including the state pension, in one place online.
The dashboards will support better planning for retirement and help individuals reconnect with lost pension pots.
To make dashboards work, multiple parties need to be connected to what is being referred to as an ‘ecosystem’ – see diagram above.
This will effectively function “like a giant switchboard’, connecting users with their pensions via dashboards.
Hymans Robertson LLP has been a positive supporter for the introduction of a pensions Dashboard for consumers from the outset and sees this development as a much needed step towards digitalisation of the industry as well as connecting consumers with lost pension entitlements.
Hymans Robertson has been actively engaged in assessing and responding to the legislation directly and through our involvement with PASA as part of the Pensions Dashboard Working Group (PDWG).
We are also directly engaging with the Pensions Regulator (tPR) and have quarterly calls in the diary with Angela Bell from the regulator who is an industry liaison and also attends the PASA PDWG.
Connect – Ensure connection to the dashboards system, by the relevant staging deadline. Most schemes are likely to do this through their third-party administrator’s integrated service / software provider.
Find and match requests – Receive personal information on dashboard users, and search and match members to their pensions.
Provide data – Provide members with information about their pension through their chosen dashboard.
Ongoing compliance – Once live, remain connected and demonstrate compliance.
Schemes now can be taking steps to review their existing scheme management process. A review of forthcoming member communications and scheme websites should also be undertaken to begin to communicate the steps being taken to become Dashboards compliant.
It is anticipated that schemes who fail to comply with regulations will see penalties issued up to a maximum of £5,000 to individuals and £50,000 in other cases.
Penalties are likely to be more robust where there is clear evidence of intentional non-compliance.
TpR recently consulted on their proposed compliance and enforcement policy. They continue to consider the responses and intend to publish a final policy later this year.
The information available on dashboards will start with simple information similar to what is already available to people on annual benefit statements. This will include details of successfully located pensions, including the pension provider, how best to contact them and the value of that pension.
It should be noted that Dashboards are not anticipated to show pensions that are already being paid.
In order to provide the connection for Dashboard Hymans Robertson identified early on that we would require a connection service which sits outside of the administration system to ensure the process is streamlined and protects our Business as Usual processing for schemes and members
We are using Civica to connect to the dashboard ecosystem (ISP service) and are partnering with Intellica to produce data readiness reporting.
Work will continue over the coming months on data readiness for clients who have early staging dates. This includes necessary data cleansing and ensuring reporting requirements can be met successfully.
Yes Hymans Robertson TPA have a project team in place and robust plan for all schemes where we provide third party administration.
As regulations continue to evolve this plan evolves accordingly.
Activity is well under way to onboard our largest clients with the earliest staging dates and the following cohorts of clients as soon as the DWP reset is complete and new dates are available. There are three parts to the project:
This is a complex project and a high priority project for TPA and we’ll continue to keep you updated with progress.
Delivering dashboards is highly complex and it is vital that industry has the right support in place to commence connection – either directly or via an integrated service provider (ISP) or administrator. Although much of the work on the central digital architecture has been delivered, there is more to do. This includes finalising the supporting documentation and ensuring a smooth and stable connection journey for industry.
In short, the DWP has not yet confirmed the overall length of the “reset”.
Currently the DWP is considering its options and will provide an update on dashboards to Parliament before Summer recess.
In the meantime, PDP is working closely with DWP, the Financial Conduct Authority (FCA) and The Pensions Regulator (TPR) on a revised and achievable delivery plan which gives PDP the time it needs to meet the significant challenges in developing the necessary architecture to deliver dashboards successfully.
DWP has said that there will be no changes to the principles of the connection windows for pension providers and schemes.
DWP is clear that the framework of the existing regulations is fit for purpose, for example around the requirements for the dashboards available point (DAP), qualifying pensions dashboard services, or requirements relating to find and view data.
TPR have written to schemes which were due to connect in 2023 and has provided a formal update regarding the reset confirming those schemes should continue to prepare focussing on Data readiness. DWP has been informally consulting with industry on the best approach to take with the rescheduling of staging dates and we expect the legislation to be updated in June / July 2023 removing the legal requirement for schemes to connect. We anticipate the updated connection deadlines will be announced in guidance later in 2023 once the program has a clearer understanding of the development required to provide the connection service to the dashboard ecosystem.
Getting ready for pensions dashboards takes time, and even though it is not currently possible to connect to the Money and Pensions Service (MaPS) / PDP dashboards digital architecture, it is important that preparations continue. This includes, for example:
DWP and MaPS remain fully committed to dashboards, which will transform how UK savers track down and engage with their pensions. Dashboards will also bring opportunities for providers and schemes to enhance engagement with their members and customers.