Dashboards – they’re inching closer
13 December 2022
It’s time to get ready for real, reports Ruari Grant, Policy Lead, DC.
I don’t quite know whether something can be a perennially ‘hot topic’, or whether if it’s around for long enough it simply becomes part of the furniture; either way, in the world of pensions policy, one could argue that pensions dashboards occupy both these roles. We’ve been discussing them for years, and while progress within the Pensions Dashboard Programme (PDP) has inched forward, much of this to date has been at the back end, somewhat out of sight, on the grandiosely named Central Digital Architecture.
That’s all about to change though. In recent weeks there’s been a flurry of publications from government, regulators and the PDP itself, and we’re now six months from the first schemes connecting into the dashboard and providing real live data.
Now in order for all providers and schemes to play ball and provide their data, legislation and regulation is clearly needed, and parliament is currently debating DWP’s draft regulations compelling all occupational schemes to connect, process and match find requests, and return relevant information. And FCA land is one step ahead; final rules are now in place requiring providers to connect and return pensions information by August next year.
The PDP, meanwhile, has been busy engaging with feedback to its summer consultation on dashboard standards. This is the framework that both data and dashboard providers will have to fit into and they set the rules on data, reporting, connection and all the technical elements of the project. In our submission we highlighted various key issues including the liability status of indicative values shown on a dashboard, data response times, and the way additional voluntary contributions are shown for DB schemes. We expect the PDP to publish its updated set of standards in the coming weeks, and also to issue a standalone consultation on the design standards. This will determine the end product – what’s actually displayed on a dashboard for a member of the public to look at.
So with the various cogs spinning, the mind naturally turns to the end product, and when we might finally be able to log on and see that coveted list of all our pensions in one place. The – as yet – undetermined point in time when this happens is known among the initiated as the Dashboard Availability Point, or ‘DAP’ for short, and in yet another recent publication the government has extended the notice period which the Secretary of State must give when announcing the DAP from three to six months. While this might seem a fairly arbitrary process, and while in practice we wouldn’t expect the announcement to come as a surprise, it is actually vital that all parties are prepared and that certain reasonable criteria are met ahead of dashboards going live to our savers.
For example, we have made clear to government that considerable testing will need to take place ahead of the DAP to ensure dashboards work as intended, and this testing ranges from accurate data matching, to the displaying of the right information, and ultimately to checking that users understand what they’re shown. Much of this will necessarily have to be carried out once most schemes are connected – so it doesn’t leave much time. Therefore, we are glad that the government will over the coming months establish key criteria for the DAP over four categories: coverage, effective operation, security, and user experience.
What comes next?
So where does all this leave you, as PLSA members? Well, if you’re a scheme, it’s likely that at some point in the next year or two you’ll be required by law to connect to the dashboard ecosystem, so we’d recommend setting up an implementation plan and engaging with your administrators – and integrated service provider if you’re using one – as soon as possible to establish what work this will entail.
We’d also recommend consulting our dashboards connection checklist for a quick overview of what you might need to consider. While the DAP itself may still seem some way off for now, with the scheme onboarding process fast approaching and the work this will entail, you can be sure it will be upon us sooner than you might think.
An action plan for all schemes
The PLSA has prepared a checklist of key actions that schemes of all types and sizes should be doing now in order to prepare for pensions dashboards.
- Know your dashboard staging date
- Check your knowledge and understanding of the requirements is complete and up-to-date
- Have a detailed compliance project plan, including budgets, resources and work required
- Understand with your providers how you will connect to the ecosystem
- Check your contracts and other documents include dashboard connection services
- Make sure all member records are digitised, or make sure you know your administrator’s plans to digitise paper-based records.
- Check your data is accurate and know what steps your administrators are taking to keep it up to date
- Make sure that pensions income data is complete and available
- Plan how you will support members’ next steps
- Understand how you will explain dashboards to members
See our website for a more detailed version of this list.
At the heart of dashboards
The PLSA has been actively involved in pensions dashboards during 2022. Our Dashboard Hub has a wealth of information to help schemes prepare.
We have taken an active role in government consultation about pensions dashboards. You can read our consultation responses online, including:
- Dashboards Standards Consultation: August 2022
- Pensions Dashboards Further Consultation: July 2022
- Proposed Revisions To Astm1: May 2022
- FCA Consultation On Pensions Dashboards Cp22/3: April 2022
- DWP Consultation On Draft Pensions Dashboards Regulations: March 2022
In addition to our 12 Months to Connect checklist, watch our two-minute explainer video, created for our 2022 Annual Conference
In March 2022, the PLSA hosted a Policy Insights webinar, where we heard from Moneyhub (one of the programme’s first dashboard providers) and Mercer (one of the first data providers) about their work to get the system up and running. ARC Pensions Law explained schemes’ key risks, and we introduced the Dashboards Hub.
Dashboards were a prominent feature of the programme at our Annual Conference 2022. A panel of Chris Curry, Principal of the Pensions Dashboards Programme; Richard Smith, Pensions Dashboards Consultant at the PLSA; Maurice Titley, Chief Innovation Officer at ITM; and Alyshia Harrington-Clark, Head of DC, Master Trusts and Lifetime Savings at the PLSA debated the deadlines looming for the project.
The session is available to watch again on demand for all conference attendees, and free for fund members and master trust members who weren’t able to make the event.
Register for our Policy Insights Webinar: Get Ready for Pensions Dashboards
Find more information and resources in our Pensions Dashboard hub