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Pensions dashboards – the staged timetable

Pensions dashboards – the staged timetable

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Volume 2024 | Issue 09

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It was a little over a year ago that a reset of the original staging timetable for connecting to the pensions dashboards ecosystem was announced. The regulations were amended to provide a new connection deadline of 31 October 2026, with supporting guidance promised which would set out the detail of when schemes would be expected to connect.

This guidance has now been published by the DWP.

Background to the guidance

Following the reset announcement in March 2023, the Pensions Dashboards Regulations 2022 were amended to introduce a single ‘connection deadline’ of 31 October 2026 for occupational pension schemes to connect to the pensions dashboards ecosystem. Similar changes were made by the FCA to the requirements for providers of personal and stakeholder pension schemes.

The guidance published by the DWP for occupational pension schemes must be taken into account by trustees as part of their obligations. If trustees are unable to demonstrate how they have taken account of the guidance, enforcement action may result from The Pensions Regulator.

The DWP is continuing to work with the FCA, The Pensions Regulator and the Pensions Dashboards Programme (PDP) to deliver pensions dashboards.

Connecting to the pensions dashboards ecosystem

The so called ‘pensions dashboards ecosystem’ is made up of pensions dashboards themselves, ‘find’ and ‘view’ interfaces with pensions providers and pension schemes (or the third parties managing connection on their behalf), and the ‘central digital architecture’. This latter component comprises three services and is what connects pensions providers and schemes with dashboards. The three services are: the identity service, the consent and authorisation service, and the pensions finder service.

Connection to the dashboards ecosystem is achieved through one of two ways:

  • using an in-house technical salutation by building their own direction connection; or
  • buying the services of an Integrated Service Provider (ISP) or third-party administrator and connecting through them.

The PDP expects to facilitate connection in two stages. The first stage will cover those using a direction connection and will begin ahead of widescale connection in line with the staged timetable. The second stage will cover those using a third-party organisation and, therefore, these are the providers and schemes that are covered by the staged timetable in the DWP’s guidance.

The staged timetable for connection

The timetable is divided into a number of different cohorts depending on the ‘number of relevant members at a reference date’. For occupational pension schemes (that are subject to the DWP’s regulations), this means the number of active members, deferred members, and pension credit members at the scheme year end date in the period between 1 April 2023 and 31 March 2024. For pension scheme providers (that are subject to FCA rules), this means the number of pension pots in accumulation across all personal and stakeholder pensions, retirement annuity contracts, pension buy-out contracts and freestanding AVCs that the provider operates for the period covered by the same scheme year end date.

This briefing note does not cover all the cohorts in the guidance.

Large schemes and providers

Essentially, schemes with 1,000 or more relevant members, should connect between 30 April 2025 and 30 November 2025. For example, money purchase schemes used for automatic enrolment with 5,000 or more members should connect by 30 April 2025. Hybrid schemes with between 2,500 and 4,999 members should connect by 31 August 2025.

Medium schemes and providers

All other schemes with 100 or more relevant members, should connect between 31 January 2026 and 30 September 2026. The cohorts are divided into groups with connection dates ending each month during the nine-month period.

Small schemes

Schemes with fewer than 100 relevant members at the reference date can voluntarily connect to the pensions dashboards ecosystem. Further guidance for this group will be published by the PDP.

New schemes and changes of administrator

The DWP’s guidance also covers new schemes and applications to defer connection following a change in administrator.

Benefits of adhering to the staged timetable

The guidance explains why schemes and providers may want to adhere to this timetable even though it is not mandatory. The DWP also reminds trustees and providers that missing the connection deadline of 31 October 2026 may result in enforcement action by the FCA or The Pensions Regulator (as appropriate). (The Regulator’s compliance & enforcement policy for dashboards is currently being finalised and should be published this summer.)

Trustees using a third-party organisation to facilitate connection should agree with the third-party what is required and ensure it is completed before the relevant ‘connect by’ date set out in the DWP’s guidance.

The Pensions Regulator’s guidance and communications

The Pensions Regulator has previously issued guidance to support schemes with connecting and supplying data to the pensions dashboards ecosystem. This has been updated to include an online tool to confirm a scheme’s ‘connect by’ date in the staged timetable.

In addition to the updated guidance, the Regulator is writing to all trust-based schemes in scope for dashboards to highlight the online tool and also confirm the legislative date by which all schemes must be connected to dashboards.

The Regulator will also send ‘nudge communications’ to trust-based schemes 12 months before a scheme’s ‘connect by’ date for those connecting in April – August 2025. Schemes with ‘connect by’ dates from October 2025 onwards will receive their first nudge 15 months ahead of this date.

A campaign will be run in early summer 2024 to encourage schemes to prepare their data ahead of their connection dates (as set out in the DWP’s guidance).

Comment

The first connection deadline in the original DWP regulations and FCA rules was 31 August 2023 following the legislation for pensions dashboards being introduced by the Pension Schemes Act 2021. On 2 March 2023, the then Parliamentary Under Secretary of State for Pensions, Laura Trott, announced a reset to this timetable, advising that “additional time is required to deliver the complex technical solution to enable the connection of pension providers and schemes”.

Following the publication of the DWP’s guidance, the current Parliamentary Under Secretary of State for Pensions, Paul Maynard, has confirmed that “the PDP has made significant progress building and testing the system which will enable pensions dashboards to work”. He says that the staged timetable “will help smooth the process of connecting the approximately 3,000 pension schemes and providers in scope by the connection deadline of 31 October 2026”.

The publication of this new staged timetable in the DWP’s guidance is to be welcomed, as it marks an important part of dashboard preparation for trustees and providers.