There have been a number of developments since our last Pensions Dashboards Update in October.

The Pensions Administration Standards Association (PASA) published the first content in its new dashboards toolkit, relating to AVC providers: a questionnaire for trustees to issue to their AVC providers; a checklist and list of activities for administrators to connect to and maintain AVC data; and a list of AVC providers and their connection methods. These releases recognise that connecting AVCs to pensions dashboards is an important issue and one on which PASA has received many requests for support.

The Minister for Pensions confirmed in a written ministerial statement on 22 October that the government is committed to the delivery of pensions dashboards, to the existing published timetable for the connection of schemes to the dashboards ecosystem (beginning in April 2025) and to the 31 October 2026 longstop.  The statement noted that “it is therefore essential that the pensions industry continues to prepare for connection, having regard to the timetable set out in DWP’s guidance.”. The statement confirmed that the government will prioritise the launch of the government-backed MoneyHelper dashboard and that there will be a period whilst only this dashboard is operational.

On 7 November the FCA published policy statement PS24/15 setting out the regulatory framework for firms that operate pensions dashboard services. The statement summarises the feedback to two previous FCA consultations and the FCA’s responses to them.  The FCA recognises that the policy statement primarily affects firms interested in operating a pensions dashboards service (and who will need to obtain regulatory permission to do so) but notes that it will also interest others, including pension providers, trustees and administrators who will be supplying information to the dashboard services.

On 19 November the Pensions Dashboards Programme (PDP) published:

  • An updated version 1.2 of its draft reporting standards (which set out requirements on pension providers and schemes for generating and recording operational information and reporting it to MaPS). The PDP does not expect to make any further changes to this version before seeking formal approval;
  • An updated version 1.3 of its draft data standards (which provide the basis for data interoperability across the pensions dashboards ecosystem). The PDP does not expect to make any further changes to this version before seeking formal approval, with any further required changes identified during testing being introduced by amending formal published standards after April 2025;
  • An updated version 1.2 of its draft code of connection (which sets out how providers and schemes connect to the dashboards ecosystem and what they need to do to remain connected). The PDP may make further changes to this code before seeking formal approval from the Secretary of State for Work and Pensions.

The Pensions Regulator (TPR) has begun to reach out to schemes in scope for dashboards to ensure that they have the right processes and controls in place around their data and will challenge those that are not able to demonstrate how they meet TPR’s expectations. TPR will also be sending surveys to chairs of trustees and scheme managers in connection with dashboards connection readiness. Trustees need to ensure that data is accurate and up to date and that a set of data matching criteria has been developed.

The latest PDP progress update is expected shortly and with developments continuing at pace it is important that trustees and providers continue to prepare for connection in line with the timetable set out in DWP’s guidance.

Pensions dashboards should by now be a regular item on trustee meeting agendas and schemes should have appropriate governance structures in place to facilitate compliance.  In addition to data accuracy and matching aspects, trustees should be considering data protection implications and whether any providers’ contractual terms need reviewing and updating. 

If you would like any advice or assistance with dashboards compliance, we are very well placed to help. Please do contact Andy Prater, Susannah Young or your usual Burges Salmon Pensions and Lifetime Savings team contact.