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Overview

Published: 22 June 2022

Last updated: 14 July 2023

14 July 2023

Failing to comply with pensions dashboards duties updated to include information on how trustees and scheme managers will be expected to demonstrate that they have had regard to the guidance on staging timelines.

8 June 2023

Rewrite of when your scheme needs to connect with dashboards to cover the new deadline and staging timeline for schemes to connect. 

15 March 2023

Significant updates throughout the guidance to incorporate the Pensions Dashboards Regulations 2022 and Money and Pensions Service standards.

20 July 2022

Updated guidance following government response to consultation on Draft Pensions Dashboards Regulations 2022.

As a pension trustee or scheme manager, you will need to connect with and supply pensions information to savers through dashboards.

The Department for Work and Pensions (DWP) has laid the Pensions Dashboards (Amendment) Regulations 2023. A revised staging timeline will be set out in guidance, and all schemes in scope will need to connect by 31 October 2026. The staging timeline will indicate when schemes (by size and type) are scheduled to connect.

There is significant work involved to comply with your dashboards duties and you may need to engage third-party suppliers to help you with this work, such as an administrator or an integrated service provider (ISP). You should work with your advisers to assess the impact of the changes and plan how you will meet your dashboard duties.

Many of the dashboards processes are still being developed. We will update this guidance when necessary to reflect further developments and the industry’s experience with dashboards. Find out more about how to stay up to date with developments.

What are pensions dashboards?

Pensions dashboards are digital services – apps, websites or other tools – which savers will be able to use to see their pension information in one place. This includes information on their State Pension. Pensions dashboards will not show pensions that are already being paid.

A saver will use dashboards to search the records of all pension schemes to confirm whether or not they are a member. For simplicity in this guidance, we use ‘member’ to refer to all dashboards users.

Dashboards aim to help members plan for retirement by:

  • finding their various pensions and reconnecting them with any lost pension pots
  • understanding the value of their pensions in terms of an estimated retirement income

The Money and Pensions Service (MaPS) will develop and host its own pensions dashboard on the MoneyHelper website. Other organisations will also be able to develop and host their own dashboards, subject to approval and regulation by the Financial Conduct Authority (FCA).

For pensions dashboards to work, MaPS is building a digital architecture which will connect pensions dashboards to pension schemes. You can find out more about the digital architecture on the MaPS website.

Which schemes are in scope?

Dashboards duties will apply to the trustees or scheme managers of:

  • registrable occupational pension schemes with 100 or more relevant members
  • public service pension schemes

A relevant member is an active, deferred or pension credit member. Members who are receiving benefits (pensioners) or whose benefits have been cashed in to provide a tax-free lump sum, purchase an annuity or drawdown income are not relevant members. However, members who have taken an uncrystallised funds pension lump sum (UFPLS) should still be considered in scope for dashboards.

The Financial Conduct Authority has made corresponding rules for FCA-regulated pension providers in respect of personal and stakeholder pension schemes.

Common in and out of scope scenarios

  • If your scheme’s main administration is in the UK, it will be in scope of the regulations, even if some sections are administered outside the UK.
  • If your scheme is in the process of buying out, you will remain in scope until the buy-out is complete. At this point, the buy-out provider will assume accountability for complying with dashboards duties.
  • If your scheme is in the process of winding up, you are still in scope, unless the number of relevant members falls to zero. However, there are some exemptions to the information to provide to your members.
  • If the whole of your scheme enters into an assessment period with the Pension Protection Fund before your connection deadline, you will be out of scope of the regulations. However, if any sections of your scheme are not in assessment, the entire scheme is still in scope, but there are some exemptions to the information to provide to your members.

Your role and legal duties

You will be required to:

You will need to do all of the above in compliance with standards published from time to time by MaPS and having regard to guidance issued by MaPS and The Pensions Regulator.

Working with advisers and providers

You will need to work with several organisations to get connected to dashboards. Typically, this will involve your administrator, software providers, actuary and legal advisers. It could also include employers (to improve the availability and quality of personal data) and external data suppliers (for example additional voluntary contribution (AVC) providers if you do not hold full details of the AVC entitlement with the main scheme information).

Talk to them as soon as you can about their dashboards plans and how they can support you. Early engagement will help them plan their workload and improve their ability to support you.

You may need to procure new services or update your supplier contracts. This will take time and may hold up your preparations if you do not address this early.

The dashboards duties apply to trustees and scheme managers. While you can use third parties to help you meet your duties, you will ultimately remain accountable for ensuring that your scheme is connected to dashboards on time and that you are (and remain) compliant with the requirements. You will need to be available to make any decisions required for your suppliers to progress their work and you should put in place robust ways to monitor this progress. Where they are supporting other clients with similar connection deadlines, make sure they have enough capacity to deliver.

For more information, see our guidance on the selection, appointment, management and replacement of any suppliers.

Discussion points with third parties

Below is a list of areas that you may wish to discuss with your third-party providers. There will be more points that are specific to your scheme. We encourage you to keep a record of your enquiries, the response and any decisions made.

  • Roles and responsibilities. It is important to be clear about the roles and responsibilities of those who are supporting you to meet your duties, and ensure there are no gaps in the process.
  • Awareness of compliance requirements. When delegating any work to third parties, make sure they are aware of the relevant compliance requirements, for example the standards set by MaPS.
  • Data review and improvement plan. Good data quality is fundamental to your dashboards duties. It is vital to work with your administrators to review and set up improvement and data control plans.
  • Monitoring progress. Put a process in place to receive regular reports and maintain audit trails for reporting purposes. We recommend you add pensions dashboards as a regular agenda item at your board meeting to monitor the progress.

MaPS standards

MaPS will set the standards relating to the practical operation of pensions dashboards services and following the digital architecture needed to support them. These standards will provide the rules and controls that will facilitate the smooth ongoing connection to pensions dashboards. MaPS has published the suite of draft standards.

  • Data standards, which set out in detail the data schemes will receive from the digital architecture, and the data schemes will need to return in all circumstances (mandatory data), in certain circumstances (conditional data), or only if relevant and available (optional data). They specify the format to use when sending data. You should also read the supporting data usage guide, which provides explanatory guidance, and the data usage examples appendix, which provides examples of the different data items for common practical scenarios.
  • Technical standards, which set out how pension schemes (or their providers) will interface with the digital architecture and user-facing pension dashboards. You need to ensure that third-party providers meet these standards.
  • Code of connection, which sets out the security, service and operational standards you will need to meet to connect to the digital architecture. This includes the timeframes you have to return data (currently under 10 seconds) and how much you need to be available (currently 99.5% of the time, measured on a monthly basis). You need to ensure that your third-party providers meet these standards.
  • Reporting standards, which set out data you will need to generate, record and supply so MaPS and The Pensions Regulator can monitor the effectiveness of pensions dashboards. This includes confirming how many times you have been unable to provide value data when requested, and why. You should be familiar with the record-keeping requirements set out in the standards and work with your third-party providers to ensure you comply with them.
  • Design standards (to be updated following consultation), which will set out requirements around presenting pensions data on dashboards and the design, including messaging, signposting and onward customer journeys.
When your scheme needs to connect with dashboards