As a reminder, the Money and Pensions Service (MPS) is responsible for creating the dashboard. The Pensions Dashboard Programme (PDP) will design and implement the hosting infrastructure required, as well as developing standards to facilitate ongoing connection to the dashboard’s ecosystem.
The connection journey
March also saw the DWP publish the staged timetable in which it expects pension schemes to get connected. The staging will take place from 30 April 2025 to 30 September 2026, and as expected, the largest schemes are required to go first to allow for crucial user testing to take place. The connection dates have been set by the number of ‘relevant scheme members’ at the end of the 2023/24 year:
- All large pension schemes and providers (including all master trusts, collective money purchase schemes, public service and parliamentary schemes, occupational pension schemes with 1,000 or more relevant scheme members, or FCA-regulated schemes with 5,000 members or more) will need to be connected by 30 November 2025
- All medium-sized pension schemes and providers (including occupational pension schemes with between 100 and 999 relevant scheme members and FCA-regulated schemes with fewer than 4,999 members) will need to be connected by 30 September 2026.
While the timeline set out in the Guidance is not mandatory, all occupational pension schemes must also meet a single backstop ‘connection deadline’ of 31 October 2026 to connect to the pensions dashboard ecosystem.
Who are the ‘relevant members’ of pension schemes?
It’s important to note that the DWP’s guidance defines relevant members as ‘active members, deferred members and pension credit members at the scheme year-end date.’ In other words, the definition of relevant members does not include pensioners – pensions dashboards will not be required to show pensions that are already being paid, or pension benefits that have been settled via either a tax-free lump sum, annuity or drawdown income.
How many schemes are likely to be connected?
Overall, an estimated 3,000 schemes are considered ‘in scope’ and need to be connected to the dashboard infrastructure by the final connection deadline. The guidelines note that schemes are expected to meet their respective connection date unless there are ‘exceptional circumstances which prevent them from doing so.’
No more connection delays likely
Pension schemes were originally expected to connect to the pension dashboard from 31 August 2023, but in March 2023, then-Pensions Minister Laura Trott announced a delay, after it became clear that many pension schemes were struggled to make all the changes required of them. Laura Trott commented at the time, “More time is needed to deliver this complex build, and for the pensions industry to help facilitate the successful connection of a wide range of different IT systems to the dashboard’s digital architecture.”
Pension schemes now have only until 8 August 2024 to make an application to defer their connection to the dashboard ecosystem, but deferral will only be granted if the scheme started a data transfer to a new administrator or recently started a new contract retendering the administration of the scheme.
"Don’t wait for me to come knocking at your door"
Paul Maynard, who was appointed Pensions Minister in November 2023, has been keen to tell the pensions industry that he is committed to the smooth implementation of the pension dashboard and that he expects pension schemes to meet their connection deadlines. In a written statement in March 2024, Maynard confirmed, “The Government is absolutely committed to delivering pensions dashboards safely and securely to the public at the earliest opportunity. The publication of the connection timetable marks a significant milestone towards launching pensions dashboards and takes us closer to introducing a service that has the potential to transform how individuals plan for retirement.”
Maynard has also made his intentions clear to the pensions industry. In February, he told delegates at the Pensions and Lifetime Savings Association’s annual investment conference in Edinburgh, “I urge all pension schemes and other providers to get their data ready ahead of connection… Don’t wait for me to come knocking at your door. I may seem cuddly now, but trust me, if I have to come to your door when it comes to dashboards, you will not enjoy the experience.”
Expectations from The Pensions Regulator
The Pensions Regulator (TPR) has said it expects trustees to take the guidance into account when making decisions on connecting to the dashboard, ‘It is a legal requirement for trustees or managers and pension scheme providers to have regard to this guidance as part of meeting their obligations and not doing so would be a breach of this requirement. As such, trustees or managers and pension scheme providers must consider it when making decisions or taking actions in relation to preparing to connect to dashboards.’
Is there a capacity crunch ahead?
There are concerns that the pension industry is still unprepared for connecting to the pension dashboard system, and that a lack of planning could lead to a serious capacity crunch as deadlines approach. A poll conducted by consultancy firm LCP, published in April, suggested only 39% of pension schemes had a plan in place for connecting to the pension dashboard system. A further 42% said they had no project plan, while 19% said they did not know.
Dashboard Operators Coalition
However, there are already some industry initiatives underway, including the Dashboard Operators Coalition (DOC) announced by Standard Life, Legal & General, Moneyhub and Just Group. The coalition has been created to ‘support the safe, secure and successful early launch of multiple pensions dashboards’ and to work closely with the Government and regulators to ensure dashboards meet the needs of their users. The DOC will be open to all potential operators of commercial dashboards.
The time to act is now
The message is loud and clear – now that the staged timetable has been announced, pension schemes need to know the deadlines relevant to them and prepare accordingly. This could include connecting to the pensions dashboard directly or using a specialist integrated service provider to help manage the process.