The DWP guidance and timetable for pensions dashboard connection

The Department for Work and Pensions (DWP) this week published its long awaited guidance setting out a staged timetable for pensions schemes to connect to the pensions dashboard ecosystem (the “Guidance”). 

Background

To recap firstly though, the 2021 Pension Schemes Act provided the legislative basis for the connection of occupational pension schemes to the pensions dashboards ecosystem.

This was then followed in 2022 by the Pensions Dashboards Regulations which introduced the requirements for occupational pension schemes to connect to the pensions dashboards ecosystem and respond to requests for pensions information. And then further amending Regulations were published in 2023 which introduced a single “connection deadline” of 31 October 2026 for relevant occupational pension schemes to connect to the pensions dashboards ecosystem.

However, the publication of the Guidance and certainty around required connection dates has been eagerly awaited with the industry in a state of flux until now. 

Staging timeline

Whilst the timeline in the Guidance is not mandatory, DWP have advised that it is designed to assist schemes with connecting to the dashboard and as such the DWP “encourage trustees or managers and pension scheme providers to follow the dates in this guidance unless there are exceptional circumstances which prevent them from doing so”. 

The staging timeline runs from April 2025 until 31 October 2026 (the connection deadline noted above), with ‘connect by’ dates set according to the size and type of scheme, based on the number of relevant scheme members as at scheme year end 23/24. You can check your scheme’s ‘connect by’ date here.

Key dates

However, some key dates are as follows:-

• Pension schemes regulated by FCA and stakeholder schemes with more than 5,000 members with 100 and DC master trusts with more than 20,000 members are being asked to connect to the pensions dashboard from 30 April 2025;
   
• DC schemes with auto enrolment and more than 5,000 members, DC master trusts with between 5,000-20,000 members, any schemes without money purchase benefits with 20,000+ members and hybrid schemes with more than 20,000 members should be connected by the end of May 2025;
   
• Public service pension schemes of all sizes have a staging date of 31 October 2025; and
   
• Smaller schemes follow after the above with the smallest schemes after having until 30 September 2026 to stage.

Relevant members

A point to note is in relation to the definition of “relevant members” referred to above. The Guidance states that the number of relevant members at the reference date (for occupational pension schemes subject to the 2022 Regulations) are the number of “active members, deferred members, and pension credit members at the scheme year end date in the period between 1 April 2023 and 31 March 2024”. 

Therefore, the definition of ‘relevant members’ does not include pensioners. This is because pensioners (and survivors) do not count as members for these purposes as pensions dashboards will not show pensions that are already being paid (or benefits which have been settled via a tax-free lump sum, annuity or drawdown income, as confirmed by the Pensions Regulator).

TPR expectations regarding compliance with the Code

The Pensions Regulator (TPR) has been communicating with the industry regarding the rollout of the Guidance and has made clear that it expects trustees to read and take the guidance into account when making decisions on connecting to the dashboard. It has confirmed that “We expect trustees to be able to demonstrate how they’ve had regard, and may consider enforcement action where necessary”. 

TPR also want trustees to demonstrate how they have had regard to the guidance. For example, it expects that trustees and scheme managers should be preparing for dashboards by engaging with the parties who will support them with their dashboard duties. 

DWP have also confirmed in the Guidance how it expects trustees and managers to comply with the Guidance - “It is a legal requirement for trustees or managers and pension scheme providers to have regard to this guidance as part of meeting their obligations and not doing so would be a breach of this requirement. As such, trustees or managers and pension scheme providers must consider it when making decisions or taking actions in relation to preparing to connect to dashboards”.

Industry reaction and other comments

Pensions Minister Paul Maynard said in a written statement on 25 March: “The Government is absolutely committed to delivering pensions dashboards safely and securely to the public at the earliest opportunity. The publication of the connection timetable marks a significant milestone towards launching pensions dashboards and takes us closer to introducing a service that has the potential to transform how individuals plan for retirement.”

The Guidance has on the whole been well received by the industry, who have welcomed certainty around connection dates. There are of course some relevant parts to the dashboard picture which are still outstanding, for example, the PDF final data standards. 

Another significant development also this week in the world of pension dashboards was the formation of the “Dashboard Operators Coalition” comprising Just Group, Legal & General, Moneyhub and Standard Life. It has been set up with the objective of collaboration, with each other, with the Government and with the Regulators to support the launch of pensions dashboards to consumers as early as possible. 

If you would like any advice or assistance with understanding how the requirements set out above for pensions dashboards will apply to your scheme, we are very well placed to help. Please do contact your usual Burges Salmon Pensions team contact, or Pensions partner, Susannah Young.

Written by Susannah Young, Mairi Carlin and Beatrice Breaden.