Consultation on draft Pensions Dashboards Regulations 2022 opens

The Department for Work and Pensions (DWP) opened a consultation on the draft Pensions Dashboards Regulations 2022 at 9:30am on 31 January 2022, running to 11:45pm on 13 March 2022¹. The consultation applies to England, Scotland and Wales, and the department says it is envisaged that Northern Ireland will make corresponding legislation¹.

The consultation sought views on a range of policy questions relating to the creation of pensions dashboards, described in the consultation document as "an electronic communications service intended to be used by individuals to access information about pensions"¹. An indicative draft of the Regulations was included "to show how we envisage the policy would be turned into law"¹. The consultation was issued under section 317(1) of the Pensions Act 2004 and covers requirements on dashboard services and their providers, and on trustees or managers of relevant occupational pension schemes, meaning occupational schemes that are not stakeholder pension schemes, in Great Britain².

The draft Regulations would apply to all registrable UK-based occupational pension schemes with active and/or deferred members, including public service pension schemes². The consultation document sets out a staging profile for scheme connection, with large schemes connecting between April 2023 and September 2024, medium schemes between October 2024 and October 2025, and small and micro schemes expected from 2026 but not covered by the Regulations². Schemes in the first staging cohort must connect in the three months before 30 June 2023². On enforcement, the document states that financial penalties for individual dashboard-related breaches can be up to £5,000 if the person is an individual and £50,000 in other cases².

The consultation document also refers to related work in progress, including a further consultation on pension reforms and changes to the consistency of projected values, with the Financial Reporting Council aiming to publish revised AS TM1 guidance by October 2022 but with an extended lead time, coming into force only from 1 October 2023². It refers to amended Disclosure Regulations expected to come into force in August 2022². The Pensions Dashboards Programme (PDP) published qualitative research with potential dashboard users, carried out by IPSOS Mori, on 25 January 2022, and its Phase One Report, published in July 2021, identified that individuals expect their personal and workplace pensions to be identified and to be informed of retirement income projections². The PDP launched a Call for Input on staging proposals in May 2021, announced the recruitment of seven major pension organisations to its test phase in July 2021, published a summary of Call for Input responses in October 2021, and in December 2021 announced the recruitment of three potential dashboard providers to the test phase².

Why it matters for households

The Regulations, once made, would set the duties that pension schemes must meet to feed information into dashboards, and the timetable by which they must connect. The staging profile means savers with larger schemes would see those schemes appear on dashboards first, from the cohort connecting between April 2023 and September 2024, with members of medium schemes following between October 2024 and October 2025². Small and micro schemes are expected from 2026 but are not covered by the Regulations². State Pension information is intended to be included on dashboards from day one, and a publicly owned dashboard service would be provided by the Money and Pensions Service, with other organisations meeting prescribed requirements allowed to develop and host their own dashboards². The consultation document states that financial penalties for individual dashboard-related breaches can reach £5,000 for an individual and £50,000 in other cases². The consultation applies to England, Scotland and Wales, with Northern Ireland expected to legislate separately¹.

What happens next

The consultation ran from 31 January 2022 to 13 March 2022 and has concluded¹. The government response to the consultation was published on 14 July 2022, and a summary of key policies was added on 15 July 2022¹. The consultation page was last updated on 15 July 2022¹.