FCA exit communications rules for pensions dashboards take effect

Rules requiring firms to tell customers when they are leaving a qualifying pensions dashboard service, and where they are being sent, took effect on 30 November 2024.

New Financial Conduct Authority rules on exit communications for pensions dashboards came into force on 30 November 2024. The rules, PDCOB 8.4.1R and 8.4.4R, sit in the FCA Handbook and set out what a firm must tell a customer at the point they leave a qualifying pensions dashboard service1.

Under PDCOB 8.4.1R, where a customer makes a choice from the choice architecture that would cause them to exit the qualifying pensions dashboard service, the firm must communicate to the customer that they are exiting the service; that their pensions dashboard view data will not be visible outside it; where they are being directed to; and that information seen after exiting will not be customised to them or their pensions dashboard view data1.

PDCOB 8.4.4R covers links provided in other circumstances that would cause a customer to exit the service. In that case the firm must comply with the requirements in PDCOB 8.4.1R(1), (2) and (4), and must also say where the customer is being directed unless it would be reasonable to conclude that this is already clear, in which case it may comply if it wishes1. The FCA gives the example of a link to the website of a particular pension scheme administrator in a customer's pensions dashboard view data, which makes clear that the customer will be directed to that administrator's website1. PDCOB 8.4.6G states that PDCOB 8.4.4R applies where a firm places an advertisement on its pensions dashboard platform with a link to a website outside the pensions dashboard service, whether or not that website belongs to the firm1.

The rules took effect on 30 November 2024, as shown by the provision dates in the Handbook. Related guidance in PDCOB 8.4.2G carries a later date of 26/06/20261.

"Firms should determine the design, form, language and delivery of the exit communications in PDCOB 8.4.1R and are reminded of their obligations under the Consumer Duty and, in particular the retail customer outcome on consumer understanding in PRIN 2A.5"
FCA Handbook, PDCOB 8.4.2G1

Separate guidance in PDCOB 8.4.3G reminds firms of their obligations in PDCOB 4 on communications, in particular the requirement that any communication must be clear, fair and not misleading1.

Why it matters for households

The rules apply to firms operating pensions dashboards, the services intended to let people see their pension information in one place. They bite at the moment a customer's choices take them out of a qualifying dashboard service, for example by following a link or an advertisement to a website outside it. From 30 November 2024, the firm must tell the customer that they are leaving, that their dashboard view data will not be visible outside the service, where they are being sent, and that what they see next will not be tailored to them or their view data1. The practical effect is that a customer moving from a dashboard to a scheme administrator's site, or to an advertised product, should be told that the dashboard protections and personalisation no longer apply. The FCA has not reported how many firms operate qualifying dashboard services or how many customers have received exit communications.

What happens next

The exit communication rules are in force from 30 November 20241. The Handbook shows PDCOB 8.4.2G, the guidance on designing exit communications and on Consumer Duty obligations, dated 26/06/20261. No further dates are given in the provisions covering exit communications.

Sources1 cited
  1. FCA Handbook - PDCOB 8.4 Exit communications requirements static-dr.dev.handbook.fca.org.uk