This guide is for financial advisers only. It mustn’t be distributed to, or relied on by, customers. It is based on our understanding of legislation as at May 2023.
‘Pensions dashboards’ will allow individuals to view all their pension savings securely in one place online. It’s hoped this will help support better retirement planning and encourage people to think more about their financial wellbeing. Specific aims connected to the launch of pensions dashboards are to:
- Increase people’s understanding of their pensions and their estimated retirement income.
- Increase people’s engagement, control and ownership of their pensions.
- Enable people to make more informed choices.
- Provide clear and simple information about an individual’s pensions, including their State Pension.
- Reconnect people with any lost pension pots.
- Lead to greater pension pot consolidation.
Pensions dashboards could also allow advisers to potentially advise their clients in a more cost-efficient way.
Recent research for the Pensions Dashboards Programme (PDP) found that 57% of people would use dashboards if they were available now, increasing to 80% among people who have three or more private pensions. It also found that the majority of people have multiple pensions - which they’d be able to view in one place on a dashboard.
The Money and Pensions Service (MaPS) is key to developing the initiative and the Pensions Dashboard Programme (PDP) is responsible for designing and implementing how pensions dashboards will operate. The PDP is implementing an ‘ecosystem’ involving multiple parties and technical services to make pensions dashboards happen and is working closely with government bodies, the pensions industry and financial regulators. Once fully operational, the pensions dashboards ecosystem will enable individuals to view all their pensions data via their chosen dashboard.
MaPS is developing a non-commercial dashboard and this will be accessible in a retirement planning hub on the MoneyHelper website. There will also be commercial dashboards operated by other organisations, including pension providers and schemes. A commercial dashboard provider wanting to offer their own dashboard will have to register it as a Qualifying Pensions Dashboard Service (QPDS) with the FCA and will also need to comply with the relevant DWP regulations and MaPS design standards. The PDP will aim to maintain alignment between dashboard providers but having multiple dashboards running alongside each other may risk confusing consumers. Legislation compels pension providers and schemes to provide member data (with consent) to the MaPS dashboard and to commercial dashboards and there will be one ‘Pension Finder’ Service, which they will have to supply their data to. The PDP has made it clear that pensions dashboards will only be made publicly available when all of its requirements, such as user security, and sufficient coverage, have been met, the system has been robustly tested and the right rules and regulations are in place.
To be able to access information on their chosen dashboard, an individual will need to follow a process along the lines of:
- Choose the dashboard they want to use.
- Confirm their identity.
- Give consent to pension providers and schemes to search for information relating to their pensions and to authorise them to provide information to the chosen dashboard.
- Submit a request to find their pensions information. The ‘Pension Finder’ service will then act like a switchboard by sending requests for information to all pension providers and schemes (it won’t actually hold the data).
- Any pension provider or scheme holding information on an individual’s pensions will return a unique Pension identifier (PeI) for each matching pension to the ‘Pension Finder’ service.
- The individual will request information on each of their pensions and the provider or scheme will return the required information in a format that can be added to the individual’s chosen dashboard. There’s a helpful video describing this process on the PDP website.
A PeI must be generated for both matches and possible matches, in line with MaPS’ standards and registered with their Consent and Authorisation Service (CAS), which manages the customer’s consent and checks they have verified their identify. Registering the PeI ensures that pension information isn’t shared with anyone without permission to view it. Any possible matches will require follow-up action to assess whether a successful match can be made.
Once identity has been verified, a match has been made and a ‘view’ request made, the information displayed will be similar to what’s currently shown on an annual pension statement. This includes administrative data, signposting to information on costs and charges etc. as well as values and projected pension information. Schemes will have the following deadlines for returning values to the appropriate dashboard:
Defined contribution – immediately where based on a value from a benefit statement in the last 13 months or generated for another purpose using the same methodology in the last 12 months. Where a value has not been generated in this way, value data must be returned within 3 working days.
Defined benefit – immediately where based on a value from a benefit statement in the last 13 months or generated for another purpose using the same methodology in the last 12 months. Where a value has not been generated in this way, value data must be returned within 10 working days.
Hybrid - the same principles apply for providing value data immediately for hybrid schemes. Where data cannot be provided immediately, the deadline depends on the type of benefits held. Schemes that offer benefits where the benefit value is calculated with reference to both money purchase benefits and non-money purchase benefits will have 10 days to provide value data whereas hybrid schemes that only contain a mixture of different money purchase benefits will have 3 days to provide value data.
Only those pension benefits not yet in payment will be displayed initially, so this excludes annuities and funds in drawdown.
Decumulation products, savings and investments could be added over time, along with the ability to carry out some transactions such as transfers.
Delegated access will be allowed for regulated financial advisers, MaPS guidance specialists and those considered appropriate by MaPS. The MaPS dashboard will have to offer delegated access but commercial dashboard providers don’t have to do so, meaning this could be a key difference in the offerings of commercial providers. The draft regulations allow an individual to export their dashboard data, which they could then share with their adviser.
Overseeing the request process is a governance register, which will ensure the dashboard ecosystem is kept safe and that the required security and performance standards are met.
Stage 1 – August 2023 to September 2024
The largest schemes with 1000+ members – starting with master trusts with over 20,000 members. This grouping also includes smaller master trusts, personal pension and stakeholder schemes, large schemes used for automatic enrolment, large occupational schemes and public sector schemes. This would potentially allow dashboards to potentially find nearly 99% of all active and deferred pension members in the UK.
Stage 2 – October 2024 to October 2025
Medium-sized schemes with 100 to 999 members.
Stage 3 – not currently set out in regulations but expected to stage from 2026
Small and micro schemes with fewer than 100 members.
The final regulations have now laid out the timelines for pension schemes to provide dashboards in these stages:
Once staged, a pension provider or scheme will need to connect into the ecosystem ready to receive find requests, locate pensions and display information. They can do this directly or through an Integrated Servive Provider (ISP) – a third-party service which will send information to the ecosystem on their behalf.
The Pensions Regulator (TPR) and the FCA will regulate the compliance of pension providers and schemes in providing data to individuals via their chosen dashboard. They are both currently working closely with the PDP.
- TPR will regulate trust-based and public sector pension schemes.
- FCA will regulate personal and stakeholder pension schemes.
Both regulators will have a range of compliance and enforcement actions they can take to penalise non-compliance, ranging from compliance and penalty notices to tribunals. Schemes may be expected to report on things such as the number of find requests received, the number of positive/possible matches, and complaints. A failure to maintain connection would also be a breach of FCA rules, and could result in supervisory or enforcement action.
A QPDS must provide management information to MaPS, TPR or the FCA when requested to do so. If they don’t comply, the FCA can ultimately de-authorise the provider. Even if they use a third-party ISP, this doesn’t remove any responsibly from the pension provider to remain operationally resilient and to meet the regulatory requirements.
The Pensions Dashboards Regulations 2022 have now become legislation, and schemes will start to stage from August 2023, although it could be a couple of years before dashboards are available to the public. There are ongoing consultations from the DWP and FCA and secondary legislation setting out how dashboards will operate is expected.
- The FCA published it’s final rules in a Policy Statement in November 2022.
- The Financial Reporting Council (FRC) has published a new version of AS TM1 on Statutory Money Purchase Illustrations. This is effective from 1 0ctober 2023 and ties in with the request for estimated retirement income to be displayed on dashboards.
- The technology build for the central digital architecture has now been delivered by Capgemini and Origo, and the PDP is making final checks to ensure this is ready for user testing of the live environment in 2023.
- TPR is consulting on its proposed compliance and enforcement policy until the end of February 2023.
- The PDP are consulting on design standards – how pensions dashboards present pensions information in a comprehensible way that’s accessible and inclusive - and this will run until the middle of February 2023.
- This will take place at the same time as the Financial Conduct Authority (FCA) consultation on their dashboards regulatory framework.
- The PDP has now published the November 2022 versions of standards (apart from design standards), i.e. covering data, reporting, technical and code of connection standards, which will come into force once they are approved by the Secretary of State for Work and Pensions.
- The PDP will provide an update on consumer protection to clearly explain the extent the of obligations of pension providers and schemes, as well as dashboards providers. This will lay out how consumers are being protected through the distributed regulatory framework, and highlight which regulator is responsible for ensuring compliance in terms of organisations’ interactions with dashboards.
- In early 2023, a connection hub will be available on the PDP website where schemes and providers can get help with the connection process. In addition, the PDP also plans to run webinars and a programme of engagement to support providers, schemes and other organisations who will be completing the process.
- TPR has also begun writing to schemes about their duties – all schemes can expect several communications, starting at least 12 months ahead of their deadline.
In the meantime, the PDP has set up a data providers hub to help providers work out what they need to do to prepare for pensions dashboards.
Pensions dashboards will go ‘live’ to consumers at a ‘Dashboards Available Point’ (DAP) and this date is likely to be set once the largest pension schemes and State Pension have staged. The Secretary of State must issue a notice to set the DAP at least six months before the specified date. Providers must undertake pre-connection steps, and therefore the rules regarding compliance with the relevant MaPS standards will come into effect three months before the implementation deadline.
More information can be found at: