It was expected earlier in the summer but better late than never, the Local Government Pension Scheme (the “LGPS”) (through the Local Government Association) has now published its “Pensions Dashboard connection guide for LGPS administering authorities” (the “Guide”) for LGPS employer and pension funds in England and Wales*, together with a specific Additional Voluntary Contribution guide for LGPS administrators. 

For an update on the progress of pensions dashboards generally, please see our earlier blog on the topic. 

Background

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.

The Department for Work and Pensions (DWP) published its dashboard guidance in March setting out a staged timetable for pensions schemes to connect to the pensions dashboard ecosystem

The long stop date for connection to dashboards by LGPS Funds is 31 October 2025. The Guide notes that TPR has confirmed that the reference to “connect by” means connecting within the month of October 2025. 

The Guide

Speaking at the PLSA conference earlier this year, The Pensions Regulator (TPR) noted that it was intended that the LGPS guidance would complement TPR’s guidance – “They work really well together but its aimed at administering authorities” noted Angela Bell, TPR’s outreach lead for pensions dashboard.

The Guide notes that it is “to help administering authorities identify the steps needed to connect to the pensions dashboards ecosystem”. And that it will help create a project plan to implement dashboards. 

It is a helpful summary of actions to be taken, decisions to be made, statutory timings and LGPS recommendations on various points, actions and timings that are not prescribed.

In line with the TPR point above, it also makes clear that TPR’s dashboards guidance should still be the starting point for administering authorities supported by the various industry guidance from the Pensions Dashboards Programme (PDP) and the Pensions Administration Standards Association (PASA).

The Guide works through all the different elements and stages of dashboard connection (e.g. who does what, governance, accuracy and digital accessibility of data, internal controls and record keeping, timescales for connection, registering with the Money and Pensions Service (MaPS), registration, how to connect to the ecosystem, authorisation and identification, matching criteria and viewing data).

It sets out all of the applicable requirements and helpfully references available industry guidance (such as the DWP and MaPS staging guidance) and information sources for reference purposes. 

AVC Guidance

The Guide does cover AVCs at a high-level in order to give an overall picture of sending “view data” (i.e. the information about each pension that shows up on the dashboard) to the dashboard ecosystem. However, it was felt that given the complexity of AVCs, it merited its own guidance and so the LGPS have produced a separate guide called ‘AVCs and Pensions Dashboards administrator guide”.

The Guide sets out a lot of practical information on topics including: reconciling main scheme records with AVC records; deciding how to send AVC view data to the ecosystem; multiple source v single source (i.e. whether the LGPS administrator sends all AVC data to the ecosystem or where it and its AVC provider both separately submit AVC data to the ecosystem); AVCs dashboard risk register and due diligence questions to ask the AVC provider.

Comment 

These look like excellent, practical guides to assist LGPS administering authorities to comply with dashboard connection requirements and all that that will entail and both Guides helpfully dovetail in with the TPR and other industry guidance available.

Given the size of the LGPS in England and Wales (86 LGPS funds), pensions dashboard connection is going to be a mammoth task and will take a significant amount of time and manpower in order to be ready to “go live” before 31 October 2025.  However, the Guide was first published in draft in November 2023 and it is clear that work has been underway to prepare for pensions dashboards for some time now. PDP was clear at the end of last year that it expected LGPS funds to have had dashboards as a regular item on the agenda for pensions committee and local pension board meetings for some time even at that point and that it expected advisory panels to ensure good progress was being made. 

*Whilst the Guides are badged for English and Welsh LGPS administering authorities, we note that the Scottish website for LGPS employers and pension funds in Scotland also has the same two Guides listed in its “Administrator guides and documents” page and so is clearly adopting the same Guides for Scotland.

If you would like to discuss this or any aspect of the LGPS and/or pensions dashboard connection requirements, please do not hesitate to reach out to your usual Burges Salmon pensions contact or pensions partner, Michael Hayles.