Update on Pensions Dashboards

7th June 2024

What do Trustees need to know about pensions dashboards? We summarise this in a helpful article, including what actions need to be taken.

Recap - what are dashboards?

The aim is to allow individuals to see their pensions information, including State Pension, for free in one place online, as well as reunite them with lost or forgotten pensions.

What actions must Trustees take?

Occupational pension schemes must connect to the pensions dashboards ecosystem and respond to requests for pensions information.

There are corresponding requirements (introduced by the Financial Conduct Authority) on providers of personal and stakeholder pension schemes.

There are two ways to connect to the pensions dashboards ecosystem:

  • using an in-house technical solution to enable direct connection; or
  • buying the services of an Integrated Service Provider (ISP) or third-party administrator and connecting through them.

Is there a connection deadline?

Yes – it is 31 October 2026 for occupational pension schemes.

Missing that deadline may result in enforcement action by the Pensions Regulator (or FCA in the case of personal and stakeholder pension schemes).

What’s new?

  • On 25 March 2024, DWP Guidance was published setting out a staged timetable for connection, with the largest schemes and providers connecting first.
  • The timetable in the DWP Guidance is not mandatory. However, it is a legal requirement that Trustees / managers of occupational pension schemes and providers of personal and stakeholder pensions have regard to the DWP Guidance. If Trustees / managers / providers are unable to demonstrate how they have had regard to the DWP Guidance, this may result in enforcement action by the relevant regulator.

What if Trustees cannot meet the DWP timetable for connection?

  • The legislation provides that in specific circumstances (and on application to the DWP), the DWP may permit deferral of connection for up to 12 months.
  • The circumstances are that there is evidence to show that, before 9 August 2023:
    • The Trustees / managers / providers had embarked on a programme to transfer the data held by the pension scheme to a new administrator; and / or
    • they had entered into a contract containing an obligation to retender the administration of the scheme and the timetable for this is reasonable and conflicts with the connection deadline.
  • Provided connection is completed before the ultimate deadline of 31 October 2026, it is not necessary to make a formal application to defer connection because of a change of administrator. However, it is recommended that Trustees / managers / providers communicate their plans with the Pensions Dashboards Programme and the Pensions Regulator at the earliest opportunity.

If you need legal advice from anything in this article

Speak to a member of our Employment, Pensions, Benefits & Immigration team

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