There has been a flurry of activity since our last update in relation to pensions dashboards connection.

On 27 March 2024 the FCA published a consultation paper on the regulatory framework for pensions dashboard service firms. The consultation closed on 8 May and the FCA aims to publish a full set of rules, perimeter guidance and a policy statement in Q4 2024.

On 30 April 2024 the DWP updated its guidance on deferred connection - the guidance sets out the issues trustees should consider if they are applying for a deferral of the connection deadline. The Pensions Dashboards Regulations 2022 allow trustees to apply to defer connection of their scheme by up to 12 months in certain circumstances relating to embarking on a change to the scheme's administrators before 9 August 2023.  The latest date for making an application is 8 August 2024.

On 1 May 2024 the PDP published an updated version of data standards as the industry prepares for connection to the dashboards ecosystem. These standards cover the data requirements for finding and viewing pensions information, setting out how data returned on a dashboard must be formatted. The standards follow on from the draft version published in 2022 which was followed by further engagement with the industry last year. Further standards and a code of connection are being refined and will be published in due course.

On 13 May 2024, the PASA dashboards working group published its Spring update confirming that it is working on guidance in relation to: AVCs, test case matrix, matching and administration readiness, with further details to follow later this year. Existing guidance will also be updated in certain areas. 

The Pensions Regulator has recently warned that trustees and administrators should look to sort out data issues soon in readiness for dashboards and has also stated that the Local Government Pension Scheme will publish its guidance for administering authorities on pensions dashboards connection soon.

Pensions dashboards preparation should now be high on trustees' agendas. Trustees should be actively liaising with their administrators in relation to data aspects and should be considering data risks and member experience and communications.  Trustees will need to consider their obligations as data controllers and will need to review and update the provisions of their administration contract in connection with pensions dashboards.

If you would like any advice or assistance with understanding how the requirements in relation to pensions dashboards apply to your scheme, we are very well placed to help. Please do contact your usual Burges Salmon Pensions and Lifetime Savings team contact, or Susannah Young or Andy Prater.

Written by Susannah Young, Andy Prater and Katy Dixon