Dashboards standards: design standards consultation and FCA regulatory framework for pensions dashboard service firms

It’s all about reducing and preventing consumer harms and confusion. Remediation for consumers if things do go wrong, which therefore encourages consumer confidence in dashboards. So, this is about design standards, but it’s also wider eg ensuring the security of the ecosystem, and making sure users have and know about routes to redress.

The discretion to choose how to display shouldn’t be seen in isolation. By requiring the dashboard to present the summary in a detailed manner, then we are building a good foundation of user comprehension and understanding. Consumers can then choose (to the extent permitted by their dashboard) to re-order the presentation (based on this understanding foundation) which they consider meets their needs.

In developing the MoneyHelper dashboard, the Money and Pensions Service (MaPS) has (and will) continue to undertake user research and testing to ensure that its proposition meets user needs and provides a good user experience.

User research by virtue of its iterative nature doesn’t lend itself to publication in the way that other research methods do, It will be helpful to share important areas of learning from research and testing on the MoneyHelper dashboard and the central digital architecture. We are looking at how these can be shared effectively.

The Government Design Principles are primarily aimed at Government’s implementation if its own services. Here we’re building a governing design standards framework for dashboards to implement. They are 2different scenarios.

Changing standards will have an impact on all dashboards and we want to make sure we give them enough notice to update their approach before we update the standards.

We want to get the balance right between stability and certainty for industry planning – a important industry request. Respondents to our earlier consultation on standards were supportive of our proposals for how we would govern the standards and manage change over time, and respondents (which we have put into place).

Our design standards are largely principle based. We think this leaves room for dashboard providers to test the design and iterate an approach that best meet the needs of their users.

In our draft design standards, the summary requires that for ERI values, where the pension is subject to tranches, the dashboard must show the total ERI payable from the beginning of the last tranche. The summary should indicate there is more important information about how the ERI could be paid in the detailed pensions information page.

Tranches could also be shown graphically on the more detailed pensions information page.

The FCA proposes that the only marketing or advertising that will be permitted on a dashboard service is financial promotions for regulated investment advice. Such promotions must comply with requirements for financial promotions in the FCA Handbook . These promotions can appear at any stage of the customer’s dashboard service journey. All other forms of advertising, including product advertising, would be prohibited under the FCA’s proposals.

A TPR regulated provider could, if it chooses, apply to become a pensions dashboard operator. The fact that it is TPR regulated does not preclude it from becoming FCA regulated for dashboard operation only.

Of course, becoming a dashboard operator is not the only way that TPR trustees and administrators (and indeed FCA regulated pension providers) can enable their members to access a pension dashboard. They could, for example, signpost to the MoneyHelperMaPS dashboard, or they could enter into a third-party arrangement with an FCA authorised dashboard operator.

We want dashboards to be usable, attractive and used as widely as possible. Our proposals are that dashboards must be at least AA compliant with the industry accessibility standard W3C Web Content Accessibility Guidelines 2.1 (or another equivalent) and must always be designed for use by those with additional or out-of-the-ordinary experiences and needs, and particularly with protected characteristics in mind (for example, we recommend avoiding the use of gendered language). Also, where a dashboard’s users could include customers in vulnerable circumstances with, for example, little pensions or financial services knowledge, the dashboard should be designed with these users in mind.

Our draft design standards do not include specific requirements on dashboards in relation to what to display following the re-direction to the central digital architecture to initiate a find request or whilst waiting to display pensions, only regarding the display of the pensions information when it is retrieved by the dashboard. We think this is a call for the dashboard. But we do set out what the scheme should do when new information has been returned to the dashboard once it has displayed the initial summary of pensions information to the user.

We consulted on our approach to the governance of standards over the Summer and published an updated version on 21 November. This sets out how we will govern change to the standards once the first version has been approved by the Secretary of State. We expect the first version of approved design standards to be published next summer and our process for change will kick in at that time.

We agree with you that if we were to make changes to design standards if v1 was introduced in Summer 2023, that the earliest date for introducing minor changes would be April 2024 (given the need for 6 months’ notice) and October 2024 (given the need for 12 months’ notice).

We want consumers to be well placed to engage in retirement planning, to take the right guidance or advice at the right time and ultimately make informed decisions. The use of dashboards might increase consumer appetite for advice or guidance. However, the information made available on dashboards (administrative details, current value and an estimate of income in retirement) are an insufficient basis alone for an FCA regulated adviser to make a personal recommendation. A full fact-find will still be required, but may be made a little more time efficient when dashboard data is the starting point, even when only part of the pension reference is exported.

The FCA is proposing to allow firms to offer certain types of data export. We are permitting firms to allow customers to export their data to themselves, to the PDS firm or to a member of the same group as the PDS firm with the permission to advise on investments (but only where this is to facilitate investment advice as a post-view service). We propose to require firms to export all view data, except the full pension reference, which can only be partially exported. This is designed to limit the value of exported data to scammers (as it prevents exported data being used to directly initiate a transaction) and we consider this requirement delivers a necessary degree of consumer protection.

The FCA welcomes views on whether this is an appropriate approach, as well as ideas on how else we might achieve this protection.

It’ll be up to the dashboard to develop its offering with consideration to the FCA Rules, the regulations and our design standards.

We are considering how we can share the insights from the MaPS user testing as it develops its prototype to ensure that its proposition meets user needs and provides a good user experience.

User research is often iterative and therefore doesn’t lend itself to publication in the way that other research methods do, but it will be helpful to share important areas of learning from research and testing on the MoneyHelper dashboard and the central digital architecture. We are looking at how these can be shared effectively.

The display of the users found pensions only lasts during the user’s dashboard session.