The DWP issued guidance on 25 March 2024 setting out the expected timetable for connection to the pensions dashboards ecosystem by occupational pension schemes, and personal and stakeholder pension providers.

Pensions dashboards will enable individuals to access the entirety of their pensions information online, in a clear format. The Money and Pensions Service is responsible for creating the dashboard, and the Pensions Dashboard Programme (PDP) is designing and implementing the infrastructure to host it as well as developing standards to facilitate the ongoing connection to the dashboards ecosystem. The Pensions Dashboards Regulations 2022 (Dashboards Regulations) originally contained a timetable for pension schemes to connect to the dashboards ecosystem. However, due to technical problems, the timetable was changed last year with the Dashboard Regulations amended to set out a single connection deadline of 31 October 2026 for all relevant occupational schemes[1]. Equivalent changes were made to the FCA Handbook for pension scheme providers regulated by the FCA.

The latest guidance sets out a new staged timetable for connection to the dashboard ecosystem. The staged guidance is to smooth the process of connecting the estimated 3,000 in scope schemes by the final connection deadline, by prioritising connection of the largest schemes to allow crucial user testing to take place. The staging will take place from 30 April 2025 to 30 September 2026. The full timetable is available here, but broadly:

  • All large schemes and providers (all master trusts, collective money purchase schemes, public service and parliamentary schemes, occupational pension schemes with 1,000 or more relevant members or FCA regulated schemes with more 5,000 or more relevant members) will need to be connected by 30 November 2025.
  • All medium schemes and providers (occupational pension schemes with between 100 and 999 relevant members and FCA regulated schemes with less than 4,999 relevant members) will need to be connected by 30 September 2026.

As guidance it is not mandatory, but the Dashboards Regulations and the FCA Handbook require trustees and pension scheme providers to have regard to guidance issued by the DWP, Money and Pensions Advice Service and TPR. Trustees and pension providers will need to demonstrate how they have considered this guidance when planning and making decisions for their connection to the ecosystem. A failure to demonstrate this on request could result in action by the relevant regulator. A recent blog by the PDP reiterates this point and states that leading pension providers have already stated their intention to adhere to the connection dates in the guidance.

HSF Comment

Trustee boards should now have pensions dashboards and how they will connect to the ecosystem firmly on their agenda. The guidance gives a clear steer that the FCA and TPR is unlikely to look kindly on schemes or providers which do not meet their connection date without “exceptional circumstances which prevent them from doing so”.

 

[1] Schemes with 100 or more relevant members must connect to the pensions dashboards ecosystem. The number of relevant members is determined at the scheme year end in the period between 1 April 2023 and 31 March 2024. Pensioners are not included in determining the number of relevant members.

 

Samantha Brown
Samantha Brown
Managing Partner (West) of Employment, Pensions and Incentives, London
+44 20 7466 2249

Michael Aherne
Michael Aherne
Partner, Pensions, London
+44 20 7466 7527

Mark Howard
Mark Howard
Of Counsel, Pensions, London
+44 20 3692 9672