Revised AS TM1 to come into force from 1 October 2023

The Financial Reporting Council's revised AS TM1 guidance comes into force on 1 October 2023, according to a Department for Work and Pensions consultation on the draft Pensions Dashboards Regulations published on 31 January 2022¹. The consultation states that the FRC aimed to publish the revised guidance by October 2022, but with an extended lead time, "coming into force only from 1 October 2023"¹.

The change sits within the wider pensions dashboards programme, which the consultation describes as intended to let people see their various pensions via a smartphone, laptop or computer¹. The consultation was issued under section 317(1) of the Pensions Act 2004 and ran until 13 March 2022, covering England, Wales and Scotland, with Northern Ireland expected to make corresponding legislation¹.

The draft Regulations set out a staging profile for scheme connection, based on scheme size:

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 or deferred members, including public service pension schemes, but not stakeholder pension schemes¹. Financial penalties for individual dashboard-related breaches can be up to £5,000 for an individual and £50,000 in other cases¹.

The consultation also records earlier dashboard work: the Pensions Dashboards Programme published a Phase One Report in July 2021, launched a Call for Input on staging proposals in May 2021 and published a summary of responses in October 2021¹. It announced the recruitment of seven major pension organisations to its test phase in July 2021 and three potential dashboard providers in December 2021¹. Qualitative research with potential dashboard users was carried out by Ipsos Mori for the programme and published on 25 January 2022¹.

Why it matters for households

From 1 October 2023, money purchase schemes must provide projections and annualised accrued values through dashboards¹. The consultation states that individuals expect, as a minimum from pensions dashboards, that their personal and workplace pensions will be identified and that they will be informed of their retirement income projections¹. State Pension information is to be included on dashboards from day one, and the Money and Pensions Service is to provide a publicly owned dashboard service¹.

Connection is staged by scheme size, so members of large schemes are reached first, with medium schemes following from October 2024 and small and micro schemes expected from 2026 but not covered by the Regulations¹. The consultation notes that some schemes may initially need time to turn around certain information on the value of pensions, with the intention that this becomes instantaneous in future¹. The consultation does not report the final content of the revised AS TM1 guidance, only the intended timing¹.

What happens next

The consultation closed on 13 March 2022, with a Government response to be published on GOV.UK summarising responses and setting out next steps¹. The consultation also refers to amended Disclosure Regulations expected to come into force in August 2022, and to regulations due to be laid in March¹. The revised AS TM1 guidance takes effect from 1 October 2023¹.