After a really busy summer, a lot of the progress the Pensions Dashboards Programme has been making is now becoming public, coming into focus, and increasing awareness across industry.
Chris Connelly
Propositions and Solutions Director, EQ
Following on from the industry call for input on the data items, we’ve had 2 further calls for input. One on security and identity verification, and then followed by proposals for staggering the start dates for industry compliance. The latter being a similar staging approach to that which we saw with Auto-Enrolment – i.e. let the larger schemes go first.
The Programme has also been busy procuring its industry partners that will be charged with delivering the infrastructure that will find and connect consumers to the dashboards using the pension schemes’ and providers’ data. Cap Gemini and Origo have been selected as the partners to deliver this central architecture. The Programme is now turning its attentions to procuring suppliers to verify and assure the identities of people using the system (be they the consumers themselves, or approved advisers).
The Programme also just announced the Industry suppliers that have volunteered as Alpha participants to help shape and test the final details of how to connect and what data to provide. EQ continue to work with the programme to help define all this detail.
Finally, last month PASA announced that it will lead a cross-industry panel to help define guidance for deciding what matching protocols each data controller should use to match a search request from a dashboard to a member in its database(s).
A really busy summer
However, all of the progress and direction in this update comes out in a week when there has been a lot of negativity in the press.
This hasn’t just been exclusive to the pensions press. Last week saw an article in a major tabloid wondering why the public do not yet know about what the programme is delivering.
The article goes on to answer itself by confirming that dashboards are still nearly 2 years away from being publicly available to consumers. I think we can assume the public may be a little too preoccupied right now to hear about when they might be able to find all of their pensions in the place of their choosing.
But this surprising burst of negativity and thoughts of preoccupation leads to the theme for this update: Do we yet know the whats, whens and whos? Because the base of these negative articles seems to be that we don’t know what it is… but we’re sure we can’t… whatever it is… do it in time.
So what do we know?
I’d summarise the current position for the pensions dashboards in one sentence: We do not know enough to finish the job, but we know plenty to get started.
The problem is that if we delay starting the pensions dashboards project until all of the i-dotting and t-crossing has finished, we’ll be too late.
We actually know a lot already. Those that aren’t too preoccupied with other things just now can find a lot of excellent information and guidance forming online. Throughout the summer, the Programme has been updating its website with lots of practical, easily digestible, pointers. Added to that, the industry bodies have been issuing their own takes on what schemes and providers can usefully do now.
Even those of you busy doing other things to your scheme, such as GMP Equalisation, scheme benefit redesign (such as McCloud remedies), liability reduction exercises such as Enhanced Transfer Values or Buy-in/out, could still be progressing towards satisfying dashboard requirements at the same time.
Useful links:
As mentioned, guidance is forming. Here is a selection of good resources:
- Are-you-ready-to-connect-compare-and-convey-Jul-2021.pdf (plsa.co.uk)
- What-Can-I-Do-Now-flier.pdf (pasa-uk.com)
And the definitive source for all Programme related materials is here:
Are we nearly there yet?
Of course, in all of your planning, you need to know “When”. The Programme has produced a useful graphic here so that you can see at a glance what the overall timeline looks like. But the key dates are these:
For the rest of 2021: Discovery Phase
The industry partners and Alpha participants will be working together through the alpha phase of the build and test phase (through until April 2022).
December 2021
Consultation on the legislation required to enable dashboards to go ahead. This will include the details of the compulsion for Trustees to provide this information, including the what’s and when’s, and also the “how quicks”.
December 2021
The next version of the data standards and technical standards will be issued to support the Alpha programme.
April 2022- April 2023
Infrastructure available to allow volunteer early on boarders prior to their legal compulsion dates.
‘Summer’ 2022
Legislation to be passed by both houses.
April 2023
The first onboarding windows start for schemes to comply with their legal duties.
When is my time to shine?
The first staging dates are 18 months away, but there is a lot to do to get ready. The recent Call for Input proposed the below scope and batting order for the first wave of onboarding.
This will prioritise FCA regulated providers of personal pensions and occupational schemes with 1,000+ members. The rationale is that you onboard the smallest number of data providers to gain the maximum number of member records (just like AE).
| Schemes | Number included in wave one |
| Master trusts | 36 authorised schemes |
| Personal pension schemes | 124 authorised providers and groups |
| Other occupational pension schemes with 1,000+ members | c1,300 schemes |
This phase (suggested to last for 2 years in total) is broken down into cohorts to help manage the number of providers onboarding at any one time:
-
- cohort one: master trusts and FCA regulated pension providers
- cohort two: other DC schemes used for Automatic Enrolment, ordered largest to smallest
- cohort three: all remaining occupational schemes with 1,000+ members, including DB schemes (private and public sector) and remaining DC schemes, ordered largest to smallest
There will be further waves after this, tackling the schemes with fewer than 1000 members down to the micro-schemes. Again, ordered largest to smallest.
What are EQ doing to help?
18 months will fly by, so we are already underway with preparations.
Last month we commenced some analysis of the data we process at EQ on behalf of our clients so we can help them target where their data needs cleaning, digitising, or where further additional automation may be beneficial. We will also be sharing our approach and high-level solution options with our software clients to help in their planning.
We will also be holding a number of direct one-to-one conversations with Trustees to get them ready for their future legal duties. We have already held the first few and so if you would like us to speak at your next Trustee meeting, please book us in with your Relationship Director.
Over the next quarter, we will be continuing to help the Programme define the details they need to feed into Alpha, and we in turn will be using this information to add more details to the design of our own technical solutions in parallel.
On the more technical side of the solution, we are working through what our connectivity propositions will be (both for our administration clients as well as our software clients). A thriving ISP (interconnectivity service provider) market will be essential to the success of dashboards.
Lastly, we are leading on the definition of the matching protocols that data controllers will need to use. We are chairing the PASA team drafting the proposals, and engaging with our peers at other software providers to deliver a joined-up recommendation to all of our clients. It is a tremendous demonstration of the willingness to collaborate for the benefits of all of our members.