Three key facts on the pension dashboard

Make no mistake, there is a big legislative and regulative push behind pensions dashboards. Several governmental and regulatory bodies are involved in making these a reality, but it’s the DWP who is in the driving seat.

Just before Parliament’s summer recess, the DWP published the feedback on its consultation earlier this year, and together with the standards from the Pension Dashboards Programme (PDP), this gives us a good checkpoint on the dashboards’ progress.

Here are three key points:

1. The timetable is slipping

The DWP will give the biggest master trusts and automatic enrolment schemes an extra two months to connect their schemes to the dashboards. And it’s very likely the FCA will also extend its timetable as well to end of August 2023. Maybe more significantly, the staging date for public sector schemes has been pushed back for five months to 30 September 2024.

As public sector pension membership stretches far and wide in the UK population, the go-live date for dashboards, arguably, can’t happen until these schemes are on board, tested, and fully connected. The Dashboard Available Point (DAP) – the go live date for the public – has not yet been announced, but this must surely put it back.

2. Matching might be challenging

The DWP has made it clear pension schemes have to walk a tightrope between two sets of regulations. On the one hand they have to stick to GDPR rules by not giving out information to the wrong person. But providers can’t take too cautious an approach as TPR and the FCA want them to match find requests to as many customers as they can.

The dashboards ecosystem is responsible for verifying the user is who they say they are, using name, date of birth, address, and photographic checks. But the provider has to set its own matching criteria. In this situation current address may not be much use – not everyone remembers to tell their pension provider they are moving house, especially in this era of e-communications.

The dashboards will encourage users to put in their National Insurance number, but it won’t be compulsory. But without this key bit of information, providers may struggle to match some people.

3. The FCA is in charge of commercial dashboards

The MaPS-run dashboard won’t be the only dashboard. Rather, other organisations – for example providers, banks or financial consolidators – can also host a dashboard. The DWP felt this would increase the chance people might just ‘stumble’ across a dashboard and search for pensions.

The FCA will set the rules for commercial dashboards – qualifying pensions dashboards services (QPDS) – and regulate them. This includes governing what these dashboards can do with the pension data they show. The DWP is clear data cannot be stored by dashboards, and no transactions or modelling are allowed. But it concedes data could be ‘exported’ out of the dashboard environment to another place on the QPDS host’s website.

The DWP is not going to prohibit the exporting of data, but it’s passing the buck to the FCA to determine the risks involved and whether exporting should be allowed. My guess is it will be, but if the FCA sees this as risky it will have to set the appropriate framework for the exported data.

Pensions dashboards are now taking shape. We know the identity checks, the information users have to put in, and, broadly, the information they will see.

How the FCA will govern QPDS firms is perhaps the biggest missing piece of the jigsaw, but we will have to wait until late Autumn until we get that detail.

This article was previously published by New Model Adviser