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Legislation Update

We start with the announcement that the Government’s Pensions Dashboards Programme (PDP) has now received royal assent, which means we now have 4 months before the Pensions Dashboard Ecosystem is ready to start onboarding schemes.


As part of these Regulations, the PDP have been continuing to progress developing the five sets of ‘standards’ which the industry will have to adhere to now that the legislation has been passed.

These have all come out for consultation at various points during the process, the last being the Reporting standards which we responded to in August 2022. Final versions of all of these will be issued over the coming weeks.

In addition to the drafting of standards, the PDP have also been continuing to develop the Pensions Dashboard Ecosystem, which includes stress and penetration testing. They are making their Test Harness available in November 2022 for providers to test connections and ‘find, view’ functionality.

Whilst progress is good, it should be noted that until the Regulations are passed, and the standards are finalised, there may be changes in requirements. To mitigate this we are working closely with PDP to ensure we understand any amendments at the earliest opportunity.

The final note is that The Pensions Regulator (TPR) will send three 'nudge' letters to all trustees at 12-15 months, 6 months, and 1 month before each schemes relevant staging date. The first ones are due out now for the relevant schemes.

What we’ve been doing

Since our last update, we have been developing the necessary functionality to ensure you are able to meet the PD regulations:

  • Our Integrated Service Provider (ISP) is built. This ‘middleware’ will allow us to connect to the PD Ecosystem and act as a filter to ensure the potentially millions of ‘find’ requests do not slow our administration systems down

  • PDP/TPR and scheme Reporting components – In development based on current draft standards

  • Compendia and Administrator core changes are in development now, with delivery targeted at the end of 2022 - these cover new PD specific tables for storing PD data attributes and processes for creating extract files

  • The file transfer for core platform extracts to upload to our ISP is built

  • Both the ‘find’ and ‘view’ request API’s are built.

The Money and Pensions Service (MaPS) have notified us that their test harness will be made available to all early participants during the week commencing 21 November 2022, to test our own API builds. We intend to take advantage of this opportunity.

In addition to the development work, we have been undertaking analysis and planning in a number of areas, including:

  • Creating a plan of all our clients onboarding dates based on the scheme information we hold. This will enable us to build out a capacity plan

  • Undertaking analysis to understand the potential increase in work volumes and how this can be mitigated

  • Creating checklists for each client so that we can help ensure no steps are missed as we help you onboard.


Next steps

Between now and your onboarding date, you need to be taking some key decisions around the following:


How do you want to connect to the Pensions Dashboard – you can either use our ISP or look at an alternative provider


What matching criteria do you want set up – for our ISP we have focussed on 4 options based on PASA guidelines


How do you want AVC data to be shown on the Dashboard – either as a combined entry or separately


Do you need to check your data quality – this will reduce the chances of partial or no matches and potentially providing data to incorrect individuals


How are you going to provide the pension value data – this is particularly pertinent to DB deferred members where historically annual benefit statements haven’t been produced


Increases in work volume after Pensions Dashboard onboarding – it’s expected that once Dashboard is live, more members will be in contact to request updates or quotes/finalisations, so we need to be planning how you want this handled.

Find out more

Your Relationship team will be helping you through this whole process backed by a team of subject matter experts, so if you need any advice or guidance, please do keep in touch with us.