Part 4 – Pensions Dashboards: a dash to the finishing line?

Key Points

• The final guidance deadlines for pensions dashboards are fast approaching, with all UK occupational and personal pension schemes of 100+ relevant members required to connect by 31 October 2026.
• Failure to connect can result in significant regulatory fines.
• Schemes must ensure technical readiness, address data and matching challenges, and engage proactively with regulators if struggling to meet deadlines.

Connection: Who, When and How?

The statutory requirements for pensions dashboards are clear and far-reaching. All UK occupational and personal pension schemes with 100 or more members, including active, deferred, and pension credit members but excluding pensioners in receipt of pension, are required to connect.[1]  Furthermore, Financial Conduct Authority (FCA) rules stipulate that providers of individual, group stakeholder and personal pensions (such as life insurance companies and operators of self-invested personal pensions) must also connect under FCA rules[2].

Once connected, schemes must be prepared to respond to two distinct types of dashboard requests for when the dashboards system becomes available to the public:

• “Find” requests: Accurately matching individuals to their pension records.
• “View” requests: Providing members with access to their pension data in a secure and comprehensive format.

In practice, most schemes will appoint an Integrated Service Provider (ISP) to manage the technical interface with the dashboards infrastructure. Some schemes, particularly those with significant internal resources, may opt to build a direct connection.

Non-compliance carries regulatory risk. The Pensions Regulator (TPR) confirmed they will “adopt a risk-based and proportionate approach to enforcing the law.” Failure to connect by the relevant deadline may result in enforcement action or financial penalties imposed by TPR; up to £5,000 per individual trustee and £50,000 for corporate trustees.[3]  A separate regulatory regime applies to FCA regulated providers[4].

The connection timetable is staged according to scheme size. The first guidance deadline was 30 April 2025 for Master Trusts with 20,000+ members. There were various guidance deadlines throughout 2025 for schemes with 1,000 + members. Moving into 2026, the following deadlines remain for smaller schemes:

A hard deadline of 31 October 2026 applies to all remaining schemes. If a scheme misses this deadline, the trustees should contact the Pensions Dashboards Programme (PDP) as a matter of urgency.

Common Pain Points

Connecting to the pensions dashboards is a major operational and technical challenge for many schemes. Several recurring difficulties have emerged across the industry:

1. Sourcing an ISP: Most schemes will rely on an ISP to manage the technical connection. However, smaller schemes and those in the process of winding up often struggle to find ISPs willing to take them on. For providers, the commercial incentive to support small or short-lived schemes is limited, leading to a shortage of options and, in some cases, higher costs or delays. Schemes in or approaching wind-up (potentially as part of a wider transaction to secure member benefits with an insurer) face a particular dilemma, which is discussed further below.
2. Data Quality and Matching Data: Schemes must accurately match dashboard users to their pension records using personal data such as name, date of birth, National Insurance number, and address. Common issues include:

• Incorrect or outdated member details (e.g., surnames, addresses, dates of birth)
• Missing or inconsistent data, especially for deferred members
• Legacy records that have not been digitised

Poor data quality not only risks regulatory action but can also frustrate members, increase costs, and undermine the effectiveness of dashboards. Schemes are urged to audit their data, improve accuracy, and digitise records where necessary.

3. Operational Readiness: Connecting to dashboards is not just a technical exercise, it requires operational readiness across the scheme’s administration, governance, and member communications. Schemes must configure technology solutions, establish clear workflows with ISPs and administrators, train staff to respond to dashboard-generated queries, and maintain robust audit trails. For many schemes, especially those with limited resources, these requirements can be daunting.
4. Cyber Security and Data Protection: The move to digital dashboards brings heightened cyber security and data protection risks. Schemes must comply with GDPR, the Data Protection Act 2018, and The Pensions Regulator’s cyber principles.[6] Trustees remain data controllers and are ultimately responsible for how member data is processed and protected. The increased use of digital tools and customer data raises the risk of cyber threats and scams, making robust security measures essential.

Reduced Requirements for Schemes in Wind-Up

There is some relief for schemes in wind-up. They are only required to provide administrative data to dashboards, not value data (though they can do so voluntarily), provided they are in the pipeline for winding up.

• Administrative data includes the scheme name, membership dates, name and contact details for the administrator, the employer’s name, and the member’s date of birth to show their retirement date.
• Value data includes details of how much pension the member has built up already and how much they may have when they retire (their ‘estimated retirement income’).

Schemes that are fully wound up by the deadline are exempt from the dashboard requirements.

What should trustees do if unable to connect by the connection deadline:

If trustees are unable to connect more than 30 days earlier or later than their scheme’s connection date, the PDP offers a “Change Connection Plans” process[7]. Schemes must notify the PDP if they plan to connect more than 30 days earlier or later than their assigned date. This is done via an online form, by providing scheme details, the original and new proposed dates, and the reason for the change. Notably, submitting the PDP form automatically notifies PDP and the relevant regulator, so there is no need to contact TPR or FCA separately.

The key message: if schemes are unable connect by their applicable date set out in the guidance, the key is to communicate early and set a new plan. This includes engaging proactively with TPR and PDP. Do not wait until the last minute and keep a clear audit trail of all communications and decisions relating to dashboard connection.

Looking Ahead

There is still no clear date as to when the public will be able to access the Pensions Dashboard. Once the Secretary of State is satisfied that the dashboard is ready for widespread use and with at least six months’ notice, the Secretary of State  will issue a notice specifying the Dashboards Available Point.[8] This date will mark the point at which dashboards become available to the public, a significant milestone for the industry.

Summary

The pensions dashboards project is entering its final phase, with the finish line now in sight. Schemes must ensure they are technically ready, have robust data and matching processes, and are engaging proactively with regulators and service providers. For those struggling to meet deadlines, early communication and clear record-keeping are essential. As the industry dashes to the finish line, the focus must remain on compliance, member outcomes, and the successful delivery of this transformative project.

Let us know if your scheme requires any help regarding connecting to the Pensions Dashboard. We would be happy to discuss.

[1] The Pensions Dashboard Regulations 2022

[2] PS22/12: Pensions Dashboards rules for pension providers

[3] Regulation 31, Part 4, The Pensions Dashboard Regulations 2022

^[4] FCA Pensions Dashboards rules for pension providers – Policy Statement – PS22/12 (November 2022).

[5] When your scheme needs to connect with dashboards

[6] Cyber security principles for pension schemes

[7] Change connection plans | UK Pensions Dashboards Programme

[8] Regulation 4, Part 1, The Pensions Dashboards Regulations 2022.

This article is for general information purposes only and does not constitute legal advice or a comprehensive statement of the law. Specific legal advice should always be sought in relation to individual circumstances.

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   • James Newcome

   • Senior Associate
   • Pensions & Employee Benefits

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   • Alice Anderson

   • Trainee Solicitor
   • Pensions & Employee Benefits

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