The Pensions and Lifetime Savings Association (PLSA) has today published a pensions industry guide to the decisions required to make initial pensions dashboards a success.
‘Pensions Dashboards A-Z’ identifies 26 key issues – labelled A-Z – that must be resolved to make the initial pensions dashboards a success. The issues relate to all the parties involved in the different layers of the dashboard ecosystem. This means the DWP, the Money and Pension Service, the Pension Dashboards Programme, regulators (especially FCA and TPR), administrators, technology providers, pension providers and pensions schemes. All will need to work closely and collaboratively together to resolve these issues.
All 26 issues are important, but the most urgent, where resolution and decisions are needed as soon as possible, are in seven key areas:
- Testing, and managing, savers’ understanding
Extensive testing is needed with a wide variety of different savers, who have differing levels of financial awareness, that they understand the information they are seeing on dashboards, and are not overwhelmed by it. The testing should also analyse what users do after seeing their information. These detailed testing results are key in defining the display standards which all dashboards must always use.
- ISP technical connections with the digital architecture & dashboards
Schemes will be largely dependent on their incumbent administration and technology providers, or newly procured ones, to deliver their dashboards compliance. So all administrators and technology providers need to be able see, and understand, published details of how they must connect with the central digital architecture, and with dashboards, including all necessary technical and security specifications and standards.
- Scheme’s continued GDPR compliance
Schemes need to be confident that, in complying with the dashboards compulsion requirements, they can continue to comply with all existing GDPR requirements. A clear statement of guidance on this by the Information Commissioner’s Office would be very helpful.
- Clarity on the liability regime
There are two separate liability aspects on which schemes need clarity: not found pensions, and pension amounts returned. If a scheme does not find a pension which they should (e.g. because personal data does not match perfectly), it will not appear on the user’s chosen dashboard. Separately, the pension amounts appearing on dashboards almost certainly won’t be how much is actually payable. Schemes need to have certainty where legal financial responsibility will rest should users take action, or fail to take action, in light of i) their pensions not being shown and / or ii) the pension amounts they see.
- Definition of View data to be returned
Schemes needs certainty on the pension amount data to be returned after a pension is found, both accrued (and, if required, projected), across all scheme types (DB, DC, etc.). As well as the detailed definition of these amounts, schemes need to know how quickly their ISPs are required to return the required data when a user requests it, as well as how recent the figures their ISPs return must be. Response times and recency could significantly impact how schemes and ISPs choose to implement their solutions.
Schemes need to know the window within which they must comply and the process for their onboarding to the dashboards ecosystem. Separately, schemes need to understand when Government intends to make pensions dashboards public (the Dashboards Availability Point or “DAP”) so they can plan their additional resources.
- Regulation of data provision
Schemes need to understand what principles will be adopted by the two respective regulators (TPR and FCA) for the dashboards compliance regimes.
The first wave of schemes stands ready to connect to the pensions dashboards ecosystem but, in order for them to do so successfully, they need clarity and certainty on all the above critical areas.
Nigel Peaple, Director of Policy and Advocacy, PLSA said: “Successfully delivering dashboards presents many significant challenges and there is much to be resolved in a short amount of time.
“We hope our guide will help the many hundreds, if not thousands, of people engaged with preparing for pensions dashboards better understand the key issues to be assessed and resolved.
“We know DWP, MAP’s Pensions Dashboards Programme and others are busy working on the issues we highlight here. The sooner the pensions industry has clarity on the seven key issues highlighted here, the sooner progress can be made.”
Mark Smith, Senior PR Manager
020 7601 1726 | [email protected]
Steven Kennedy, Senior PR Manager
020 7601 1737 | 07713 073024 | [email protected]