The Department for Work and Pensions (DWP) has published guidance on 25 March 2024 (Pensions dashboards: guidance on connection), a significant step in the ongoing development of the pensions dashboards project. We previously reported on the changes towards one statutory connection deadline, with a staging timetable to be set out in further guidance.
Background
By way of recap, the long term aim of pensions dashboards is to enable non-pensioner members to view all their pension savings in one place online. With the latest DWP guidance, scheme trustees now have a clearer roadmap and specific obligations to fulfil on the compliance journey.
The statutory framework for pensions dashboards is provided in the Pension Schemes Act 2021, whilst the detail is set out in the Pensions Dashboards Regulations 2022 (the “Dashboards Regulations“). These regulations have since been amended as of 9 August 2023.
Initially, the pensions dashboard service will be provided by the Money and Pensions Service (“MaPS“). MaPS has established the Pensions Dashboards Programme (the “PDP“), which is a team tasked with designing and implementing the infrastructure for the initial dashboard by MaPS.
The concept of pensions dashboards emerged in response to the increasingly fragmented nature of pension saving in the UK. With individuals often accumulating multiple pensions throughout their working lives, tracking these scattered pension savings is often a challenge. Pensions dashboards aim to address this by consolidating all the key information savers require to keep track of their retirement savings.
The Government has dispensed with the principle of statutory connection deadlines, instead retaining an ultimate connection deadline of 31 October 2026 for trustees of schemes in scope and FCA-regulated pension providers.
DWP’s latest guidance builds upon earlier iterations, offering a more granular framework for schemes and providers. It introduces a new phased connection timeline for schemes to connect and establishes clearer technical standards and data requirements.
DWP guidance – Compliance
Whilst the DWP’s guidance is non-statutory, trustees and scheme providers must “have regard” to its contents – essentially, they must consider the guidance when making decisions about connecting to the dashboards ecosystem. They should be prepared to articulate how they have evaluated the guidance and arrived at informed decisions prioritising the best interests of scheme members.
It is well known that the Pensions Regulator (“TPR“) has clear expectations for trustees to take proactive steps to prepare for the introduction of pensions dashboards. To date, TPR has adopted a proportionate approach to compliance, though it’s clear there could be potential action by TPR against schemes which fail to meet their obligations.
Trustees are advised to complete TPR’s checklist for connecting a scheme to pensions dashboards, to help demonstrate compliance with TPR’s recommendations and with the Dashboards Regulations.
Specific requirements and timelines
Amongst other things, the guidance refers to the all-important connection timelines (the guidance timeline for schemes to connect to pensions dashboards depending on type and size). The DWP state that connecting by the dates set out in the guidance has additional benefits to schemes and providers which include:
- Being in a good position to achieve compliance by agreeing a practical delivery plan with their suppliers;
- Providing sufficient testing time to enhance their members’ experience of using dashboards; and
- Demonstrating good governance and robust risk management.
Connection timetable
The DWP’s guidance sets out a list of connection dates, depending on scheme type and size. Here is a list of the key dates:
| Scheme type | Connection deadline |
| DC master trusts (20,000 + members) | 30 April 2025 |
| FCA regulated operators of personal pension schemes, stakeholder pension schemes, retirement annuity contracts, pension buy-out contract, “section 32” policy or freestanding AVCs (5,000 + members) | 30 April 2025 |
| Hybrid schemes and DB schemes (20,000 + members) | 31 May 2025 |
| DC schemes used for automatic enrolment (5,000 + members) | 31 May 2025 |
| Other large schemes (1,000 + members) | Between 30 June 2025 – 30 November 2025 |
| Public service pension schemes | 31 October 2025 |
| Medium schemes (100 – 999 members) | Between 31 January 2026 – 30 September 2026 |
As mentioned above, the ultimate statutory connection deadline for all schemes in scope is 31 October 2026. Schemes with less than 100 or more active and deferred members do not have to connect by any of the above deadlines. However, there remains an option for such schemes to apply to MaPS to connect on a voluntary basis.
Practical considerations for Trustees
There are numerous compliance obligations for Trustees to consider when ensuring their scheme is ready to meet the relevant connection deadline and to respond appropriately to ‘find’ and ‘view’ requests. The following are likely to be just some of the key aspects trustees will need to engage with to evidence such compliance:
- Data quality and completeness: Trustees must prioritise assessing the accuracy and completeness of scheme data. TPR guidance states that, if data is not reliable, trustees risk retrieving data for the wrong person, or not finding a pension record when trustees should. This could lead to enforcement action by the Information Commissioner’s Office or by TPR. Identifying and rectifying any gaps or inconsistencies early in the process is therefore crucial to minimise risk.
- Member communication: Clear and effective communication with scheme members is essential. Trustees should proactively inform members about the forthcoming pensions dashboard, its benefits, and the timeline for their scheme’s connection.
- Engaging with third-party administrators: Trustees should ensure that their administrators and/or any integrated service provider the trustees decide to use are aware of the staged timetable and are actively preparing for connection.
- Project planning and resource allocation: Connecting to the pensions dashboards ecosystem is a complex project that requires careful planning and adequate resource allocation. Trustees should develop a comprehensive project plan to ensure their scheme is in a position to comply prior to their connection date.
WB comment
The DWP’s recent guidance on pensions dashboards provides a clearer roadmap for trustees and scheme managers, outlining their obligations and timelines for connecting to the new system. This marks a significant step towards greater transparency in the pensions landscape, empowering individuals to access and manage their retirement savings more effectively.
However, the guidance also underscores the importance of data accuracy and member communication. Trustees must prioritise addressing any data deficiencies to ensure reliable information is presented on the dashboards, as inaccuracies could undermine member confidence and lead to regulatory scrutiny. Additionally, clear and proactive communication with members is crucial to educate them about the benefits and implications of pensions dashboards, maximising engagement and understanding. The phased connection timeline, with varying deadlines depending on scheme type and size, will require careful coordination and resource allocation to ensure a smooth transition for all schemes in scope.