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PDP webinar: progress update report (October 2023)

This webinar provided an update on pensions dashboards, giving detail on PDP’s progress over the last 6 months.

Chris Curry, PDP’s Principal, was joined by PDP colleagues David Marjoribanks (Senior Policy Manager) Rita Patel (Lead Analyst) and Julie Anderson-Hill (Senior Industry Engagement Manager).

These Q&As detail the questions asked by attendees and the answers given by the panel during the webinar.

PDP webinar - progress update report (October 2023)

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Guidance

How is the connection guidance different to the connection deadline?

The connection deadline of 31 October 2026 is the date by which all pension providers and schemes in scope must have connected to the pensions dashboards ecosystem.

Dates for when individual pension providers and schemes should have connected will be set out in guidance. Providers and schemes will be grouped together over different stages in connection windows. This will work in a similar way to the previous staging profile in legislation, in order to stagger connections.

Pension providers and schemes must be able to demonstrate they have had regard to the guidance when making decisions about when they will connect. They will be advised to connect to dashboards according to the timeline.

When will staging start? And will providers and schemes have 12 months ’ notice from that point to connect?

Engagement on the guidance will begin shortly, which will include the phasing and start of staging. We will be facilitating sessions with the connection forum and other industry groups.

Partners remain committed to allow industry enough time to prepare for connection. The aim is to publish the guidance with at least 12 months’ notice ahead of the first connection dates.

In the meantime, you should continue to prepare your data and select a route to connection.

Is there a danger that requiring schemes to ‘have regard’ to guidance on staging dates is setting the bar too low? One can have regard to the date and nonetheless stage later.

The legislation requires that pension providers and schemes have regard to guidance. They will be expected to be able to demonstrate how they have considered the guidance and how it has informed decision-making. The regulators will factor this into their approach to compliance and enforcement.

We would strongly encourage schemes and providers to work with their administrators or integrated service provider (ISP) on preparations for connection to help ensure adherence to the dates in guidance.

How will PDP communicate when guidance is published? And ensure that people adhere?

When guidance is published, PDP will share with industry information across a wide range of channels. Updates will be made available on our website, via webinars, on social media channels and through our engagement channels.

The regulators will be communicating with schemes and providers as well.

We have been encouraged by the feedback we have had from leading pension providers who have stated their intentions to adhere to connection dates in guidance.

Under the previous legislation for FCA regulated pensions it meant that all types had to connect on the earliest date. This included some older complex products. Is that likely to change when we get the guidance with connection dates?

Engagement on the guidance will begin shortly, which will include the phasing and start of staging. This will cover FCA-regulated providers of personal pensions as well as occupational pension schemes.

Programme timeline

When will you be publishing your revised programme timeline?

PDP has been focusing on producing a new programme plan as part of its reset activity.

We need to ensure the programme is able to facilitate pension providers and schemes completing connection by 31 October 2026.

The refreshed plan will include prioritising work on preparing for connection, with resourcing dedicated to achieving this goal. The approach is also designed to provide adequate time to take into account the different needs of those providers and schemes who are building their own route to connection versus those who are buying a third-party connection solution.

Once engagement on the guidance has begun, further programme milestones will be shared.

Connection

When will PDP be ready to start connecting providers?

The programme is working closely with over 20 organisations building a direct route to connection. The volunteer participants include integrated service providers (ISPs), administrators and pension providers.

We will work with this group to begin their connection to the central digital architecture before the start of the wider industry connection dates in guidance.

Sufficient time has been built into the new programme plan to support this activity and ensure that ISPs and administrators are ready to begin connecting clients and their schemes in line with the guidance.

If other schemes or pension providers are intending to build a direct route to connection and are not in touch with the programme, it is important they make contact as soon as possible via [email protected].

Will scheme sizes be retested? Legislation currently bases size on old data.

The revised staging profile is based on updated data, not the data used to inform the staging profile in the previous legislation.

Dashboards available point (DAP)

When will the dashboards available point (DAP) be? And, if there is coverage, can DAP come before the connection deadline of 31 October 2026?

Currently, a specific date for DAP cannot be determined.

It will be when the Secretary of State for Work and Pensions is satisfied that the dashboards ecosystem is ready to support widespread use by the general public.

This will be following consultation with the Money and Pensions Service (MaPS), The Pensions Regulator (TPR) and the Financial Conduct Authority (FCA).

The amended regulations have not altered this position. The Secretary of State will provide notice at least 6 months ahead of DAP.

Factors will be considered including sufficient levels of coverage, assurance of the safety, security and reliability of the service, and testing of the user experience.

If pension providers and schemes connect in line with the staging profile set out in guidance, then DAP could come before the connection deadline.

Can a qualifying pensions dashboard service (QPDS) go live before the 31 October 2026 deadline?

The timing of the availability of commercial dashboards (qualifying pensions dashboards services) depends on:

  • the government’s legislation to make provision of a dashboard regulated activity
  • the finalisation of the Financial Conduct Authority’s regulatory framework and the opening of the authorisations/variation of permissions gateway
  • and the finalisation of PDP design standards

Testing

How can industry (including volunteer participants) join the user testing group? And when will insights be shared?

To register your interest in joining the user testing group, or one of our delivery groups/forums, please visit our website or email us at [email protected].

When insights are available, PDP will share via our website, newsletters, blogs and other communications activity.

You can sign up to receive regular programme updates, including our FAQs newsletter.

How will the ‘real users’ be able to ‘sign up’ for testing? Will sub-sections of schemes be invited to test?

Real users before the dashboards available point (DAP) will need to be invited in, as the service will be in private beta.

We will develop these plans in the user testing group, which will involve industry, as to who to invite and when.

We expect to start with very small numbers when the connection guidance begins. Providers involved may wish to start with their own employee scheme for example, and then broaden out to other groups. Insights will be shared with industry as we begin this work to support operational planning.

This will start with the MoneyHelper dashboard and then begin to include authorised qualifying commercial dashboards once connected.

When can industry start testing with PDP? And can you explain the difference between volunteer participant testing and live user testing?

There are different types of testing.

Conformance and compliance testing is the activity that integrated service providers (ISPs)/administrators, or those building a route to connection, will need to carry out in order to connect to the live environment.

These are referenced in the Code of Connection, and this activity takes place in a pre-production environment before entering into a live environment.

Consumer testing is when we will start testing with real data. This will begin with small numbers when the guidance begins, gradually increasing over time. This testing will allow providers and schemes to test data matching as well as begin to understand user behaviour.

More information on testing can be found in our previous FAQs newsletter on testing.

If an organisation connects earlier as part of the testing phase, what are the regulatory implications if that testing fails for that provider?

Compliance with all of the duties set out in legislation, including the PDP standards, is a requirement following connection.

If a pension provider or scheme comes to PDP to connect but encounters challenges during the technical testing and is not able at that point to successfully complete connection, this would not necessarily mean they were non-compliant. They would be non-compliant, however, if they failed to connect by the deadline. Beginning the connection process and starting technical testing with PDP does not trigger the duties – connection does.

What will dashboards look like?

Are there any examples available of what the dashboard (MaPS) will look like from a user perspective?

The design standards describe the look and feel of dashboards, and set the standard for how information should be displayed.

A draft is available on the PDP website and a further draft will be engaged on in late spring/early summer.

The MoneyHelper dashboard is in development and will be the first dashboard to test with real data. We will share images as soon as possible.

Once the Financial Conduct Authority (FCA) rules have been published, we will begin working with qualifying commercial dashboard providers on connection.

Who will handle any issues of accuracy with pension information displayed on the dashboard? For example, if users think it is not correct/fully up to date.

Accuracy of data returned to members via dashboards is a matter of pensions providers’ and schemes’ compliance with their obligations.

However, if a dashboards user has any problems, they may not necessarily know to whom they should address their queries. PDP will build a central queries triaging tool with the aim to help a consumer to get to the right place when they have a complaint or an issue.

Will the technology enable PDS firms to host dashboards through mobile apps?

Yes, qualifying dashboard providers will be able to provide their dashboard on an app.

The technical architecture is agnostic as to whether dashboards are operated through mobile apps and/or websites.

Wealth and Assets Survey

What level of confidence do you think we can place in Office for National Statistics (ONS) underlying Wealth and Assets Survey (WAS) pensions information?

Pensions are complex and it can be difficult for survey respondents to know details of their pensions.

As part of the WAS process, respondents are asked to consult documentation on pensions, which helps to mitigate self-reporting error.

What was the purpose of the survey in relation to dashboards? And what has PDP learned?

The secondary analysis of the Wealth and Assets Survey was commissioned to help the programme understand the picture of pension ownership in Great Britain, as there is no administrative data that provides this information.

This information adds to the evidence base that the programme uses to inform decision making.

Why do we think more men have defined contribution (DC) pensions than women?

It is not possible to find out from the survey why more men report having DC pensions than women.

These differences are likely to be a result of labour market and therefore pension participation. There are differences in wages, types of employment (private sector or public sector), whether full-time or part-time, all of which will feed into what types of pensions individuals have.

ID verification

How is GDPR being addressed particularly for the live connection stage?

UK General Data Protection Regulation (UK GDPR) applies to the movement, processing and storage of personal data.

Dashboards will involve personal information being processed at scale. PDP is creating the pensions dashboards ecosystem, standards and processes with these data protection principles at its heart. It applies data protection by design principles as an integral approach to all ecosystem design processes and components.

Engagement

Is there any reason that none of the volunteer participants come from any of the public sector pension schemes?

A number of this group work with these schemes to prepare for connection.

The group represent those who are building a direct route to connection, as opposed to connecting via a third-party.

Department for Work and Pensions (DWP) State Pension are also working with the programme on connecting to the ecosystem directly.

PDP is not currently aware of any public sector pension schemes building a direct route to connection, but anyone considering building should get in touch with us as soon as possible.

Standards

When do you expect to publish final standards?

PDP is empowered by law to set standards providing the rules and controls facilitating ongoing connection to the dashboards ecosystem.

This includes data standards explaining how pensions data that will be returned on a dashboard must be formatted by pension providers and schemes.

In 2022 and 2023, we held consultations on dashboard standards, and draft versions of the documents were published in late 2022.

Further engagement on standards will take place over winter 2023/24 on refinements, ahead of final publication and approval by the Secretary of State for Work and Pensions.

It is intended that data standards will be made available ahead of other standards, timed to coincide with publication of connection guidance.

What do the standards include?

PDP has undertaken extensive consultation with the industry and others, and will continue to do so, in order to produce a set of dashboard standards that are deliverable and effective.

The current draft standards are available on the PDP website.

The different categories, such as data standards and technical standards, are set out in legislation and will not be amended by the revised regulations.

Some of the standards do however need further revisions to reflect industry feedback and technical developments.

PDP will provide further updates, when possible, to outline how we will engage with industry on these changes.

These documents will be finalised and will then require the approval of the Secretary of State for Work and Pensions ahead of connection starting. We recognise the need to allow industry time to prepare for connection, and will factor this into our plans for publication of the approved standards.

Can we have a draft version of the State Pension display standards?

State Pension display standards are not part of PDP’s delivery. It is the responsibility of the Secretary of State for Work and Pensions to publish any state pension information standards.

Other

Will employers running workplace pensions have any tasks or responsibilities with pensions dashboards?

Employers may wish to support their employees with engaging with their pensions by promoting a dashboard or signposting to retirement planning services as many already do.

Pension providers may signpost to dashboards in their member communications, or provide their own dashboard.

Who determines which dashboard providers are used and what would be the difference between them?

Provision of a pensions dashboard will be a regulated activity, so all dashboard providers will need authorisation from the Financial Conduct Authority (FCA). All dashboard providers will have to follow the same FCA conduct rules and the PDP design standards.

Is it expected that the MoneyHelper dashboard will replace our own customer dashboard/portals?

Provision of the MoneyHelper dashboard is a statutory requirement for the Money and Pensions Service (MaPS) and is part of MaPS’s pensions guidance function.

The MoneyHelper is intended to ensure people can always access a non-commercial public service dashboard and to supplement MaPS’s wider pensions guidance services, not to replace anything else.

Is the dashboard for members only or will independent financial advisers/consultancy businesses have access to it as well to check for members?

A fundamental premise of the dashboards service is that the individual themselves is always in control of access to their information. Only the individual will be able to use the service to find their pensions.

Are there any plans for non-UK pensions to be included?

The scope of the service is defined by legislation. PDP is not able to amend the scope.

What is the expected user outcome for dashboards? How will success be measured?

Pensions dashboards will enable individuals to access most of their pensions information online, securely and all in one place.

Dashboards will connect, and re-connect people with all their pensions, including lost posts. People should be able to see their estimated retirement income across different pension schemes.

Dashboards should contribute to people’s overall financial wellbeing and support better planning for retirement. They will empower users to make more informed decisions about their pensions and have a better understanding of their pensions information.

Notwithstanding the actual result of the next general election, do Labour have a formal position regarding continuing with the pensions dashboards?

There is cross-party support for dashboards and the goal of helping people clearly understand and be better engaged with their retirement savings.

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Author:
Pensions Dashboards Programme

Published: 01 November 2023

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