Large pension schemes to connect to dashboards digital architecture from April 2023

The Department for Work and Pensions published a consultation on the draft Pensions Dashboards Regulations on 31 January 2022, with responses due by 13 March 2022¹. The consultation, made under section 317(1) of the Pensions Act 2004, covers requirements on pension dashboard services and their providers, and on trustees or managers of relevant occupational pension schemes in Great Britain¹. It applies to England, Wales and Scotland, and it is envisaged that Northern Ireland will make corresponding legislation¹.

The proposed staging profile sets out when schemes must connect to the digital architecture. Large schemes are to connect between April 2023 and September 2024, medium schemes between October 2024 and October 2025, and small and micro schemes are expected from 2026 but are not covered by the Regulations¹. Schemes in the first staging cohort must connect in the three months before 30 June 2023¹.

The Regulations would apply to all registrable UK-based occupational pension schemes with active and or deferred members, including public service pension schemes¹. Stakeholder pension schemes are excluded from the definition of relevant occupational pension schemes¹. Financial penalties for individual dashboard-related breaches can be up to £5,000 where the person is an individual and £50,000 in other cases¹.

The consultation sets out related work on data standards and disclosure. The Pensions Dashboards Programme was to publish UK GDPR guidance in summer 2022¹. The Financial Reporting Council aimed to publish revised AS TM1 guidance by October 2022, with the changes coming into force only from 1 October 2023¹. Amended Disclosure Regulations were expected to come into force in August 2022¹. The Government said it would consult in the first quarter of 2022 on changes seeking to improve the consistency of projected values¹.

The consultation also records earlier programme milestones: a Call for Input on staging proposals launched in May 2021, a summary of responses published in October 2021, and the recruitment of seven major pension organisations in July 2021 and three potential dashboard providers in December 2021 to a test phase¹. Qualitative research with potential dashboard users, carried out by Ipsos Mori for the programme, was published on 25 January 2022¹. The programme's Phase One Report, published in July 2021, found that individuals expect, as a minimum, that their personal and workplace pensions will be identified and that they will be informed of their retirement income projections¹.

Why it matters for households

The staging profile determines when a person's pension scheme will begin returning information to pensions dashboards, the services intended to let people see their pensions in one place. Under the proposals, members of the largest schemes would be covered first, from April 2023, with members of medium schemes following from October 2024 and small and micro schemes expected from 2026¹. State Pension information is to be included on dashboards from day one¹. The Regulations cover occupational schemes with active or deferred members, including public service schemes, but not stakeholder schemes¹. The consultation does not report a confirmed launch date for consumer-facing dashboard services, and no final connection deadlines have been reported, since the staging profile was still a proposal at the point of publication¹.

What happens next

The consultation closed on 13 March 2022¹. The Government said it would publish its response on GOV.UK, summarising responses and setting out proposed next steps¹. The draft Regulations were due to be laid in March¹.