The DWP has published a consultation and draft regulations relating to the creation of pensions dashboards. The consultation covers both the criteria to be met by a provider of a "qualifying pensions dashboard service" (QPDS) and the requirements to be met by UK occupational pension schemes, including by when, as well as enforcement action. With the consultation running to more than 130 pages and additional material published by the Pensions Dashboard Programme (PDP), this e-alert concentrates on the requirements for schemes but the proposals contain many more details.
As anticipated, the draft regulations set out a timetable for staging which is roughly divided into months. This prioritises schemes by a combination of their size (number of actives and deferreds for the scheme year ending in the year to 31 March 2021) and expected ease of deliverability (broadly with master trusts and then other money purchase schemes staging first). There will be three staging cohorts: 1000+ members (April 2023 – September 2024), 100 to 999 (October 2024 – October 2025) and fewer than 99 (expected from 2026, but not covered by the Regulations).
Key to the process is for schemes to be able to immediately identify whether they hold benefits for an individual based on personal information entered into a QPDS/MaPS dashboard such as their date of birth. This is known as matching. The consultation sets out the tightrope that trustees need to walk between balancing their duties under UK data protection legislation to avoid disclosing an individual's data to the wrong person and their dashboard duty to match and return a member's data to a QPDS/MaPS dashboard. The consultation sets out the process in detail, including the situation for partial matches when the trustees can go back to an individual who then has 30 days to provide additional information. As before, the legislation leaves it to trustees to decide how to match, but indicates that The Pensions Regulator (TPR) will be producing guidance and acknowledges the Pension Administration Standards Association work in this area.
Following a request by a QPDS/MaPS dashboard, 'administrative' data (eg contact details) and signposting to websites covering prescribed information (eg member-borne charges) must be returned immediately, as should 'values' data (the accrued and projected pension) where this has already been calculated. DWP notes this might mean investment in automation or better storage of pensions data and strongly encourages schemes to consider acting now. Where values have not previously been calculated, schemes will have three working days to provide values, extended to 10 days where there are non-money purchase benefits. DWP reiterates that user testing supports showing 'values' from staging. There are two notable developments for estimated retirement income (ERI):
Pensions in payment, including drawdown, will not be included in the dashboard.
The consultation closes on 13 March 2022. Responses will "inform the further development of the Regulations" before they are laid for debate before Parliament, later in 2022 "when parliamentary time allows". Further dashboard-related consultations are expected from various bodies including the Financial Conduct Authority, TPR, FRC and PDP.
