Consultation on draft Pensions Dashboards Regulations 2022 closes

The Department for Work and Pensions (DWP) consultation on the draft Pensions Dashboards Regulations 2022 closed at 11:45pm on 13 March 2022¹. It had opened at 9:30am on 31 January 2022¹. The consultation sought views on the draft regulations, which set out requirements for pensions dashboards, described in the consultation as "an electronic communications service intended to be used by individuals to access information about pensions"¹.

The consultation applied to England, Scotland and Wales, and the DWP said it envisaged that Northern Ireland would make corresponding legislation¹. It was issued under section 317(1) of the Pensions Act 2004 and covered relevant occupational pension schemes, meaning occupational schemes that are not stakeholder pension schemes, in Great Britain². The regulations would apply to all registrable UK-based occupational pension schemes with active and/or deferred members, including public service pension schemes².

The draft regulations set out a staging timetable for scheme connection, beginning with the largest schemes. Under the proposals, large schemes would connect between April 2023 and September 2024, medium schemes between October 2024 and October 2025, and small and micro schemes were expected from 2026 but were not covered by the regulations². Schemes in the first staging cohort would have to connect in the three months before 30 June 2023².

The consultation document also set out proposed penalties for breaches. Financial penalties for individual dashboard-related breaches could be up to £5,000 where the person is an individual and up to £50,000 in other cases². The document stated that the Pensions Dashboards Programme would set out data protection detail more clearly in a UK GDPR publication due in the summer of 2022².

The consultation document also referred to related work: the Financial Reporting Council aimed to publish revised AS TM1 guidance by October 2022, with the guidance coming into force only from 1 October 2023, and amended Disclosure Regulations were expected to come into force in August 2022². It noted qualitative research with potential dashboard users carried out by Ipsos Mori for the programme and published on 25 January 2022².

Why it matters for households

Pensions dashboards are intended to let people see information about their various pensions in one place, including State Pension information from day one². The regulations consulted on would place duties on the trustees or managers of occupational pension schemes to connect to the dashboard system and to return information about individuals' pensions¹. The staging timetable means savers with pensions in the largest schemes would be covered first, from 2023, while those whose pensions sit in small or micro schemes would wait longer, with connection expected from 2026 and not covered by these regulations². The consultation document also set out that the Money and Pensions Service would run a publicly owned dashboard service, and that other organisations meeting prescribed requirements could develop and host their own dashboards². The rules on who may operate a dashboard service, and the new regulated activity, involve FCA authorisation². Supervision of scheme compliance sits with The Pensions Regulator².

What happens next

The DWP said it would publish the government response to the consultation on the GOV.UK website, summarising responses and setting out proposed next steps². The GOV.UK page records that the government response to the draft Pensions Dashboards Regulations 2022 was published on 14 July 2022, and a summary of key policies was added on 15 July 2022¹. The page was last updated on 15 July 2022¹.