PDP webinar: connection and progress update

Welcome to today's pensions dashboards program webinar. My name is Joe Stacy, and I'm a senior industry engagement manager at PDP. I'd also like to introduce our speakers today. Alongside me, I have John Higgins, who's a policy lead on pensions dashboards at DWP, and You Yu, who's a policy delivery lead at the pensions regulator. This session is being recorded and will be published on our website. Please add any questions you may have into the questions box, and we'll look to pick up as many as we can after the presentations.

In this webinar, we will provide you with a progress update on the pensions dashboards program and more information on the recent publication of DWP's connection guidance, the staged timetable, and TPR's approach to compliance. For the last six months, the program has been working hard with delivery partners and industry to support preparations for connecting schemes and providers to the dashboard's architecture. The DWP stage timetable for connection was published in March, and John will provide more details on this later. We have also continued to work closely with our cohort of volunteer participants who are connecting directly to the central digital architecture. This is in preparation for connecting and testing with them later this year, ahead of the wider industry staging activity from 2025. Our volunteer participants are playing a crucial role in helping PDP develop standards and other supporting materials, which will be made available more in the coming weeks and months. Industry, the government, and regulators continue to show a collaborative spirit, and the whole team at PDP and MAPS remain grateful for the hard work and commitment that is going into making pensions dashboards a reality.

Before we move on, I want to mention PDP's appointment of a senior responsible owner (SRO). A long-held plan for the program was to appoint an SRO with digital technology experience to help support and ensure delivery of the program. I'm pleased to announce that Ian Patterson will be joining us from the central digital and data office, which is part of the cabinet office where he was a senior strategic technology advisor to the legacy program. This appointment will strengthen the program as it continues to deliver the ecosystem for pensions dashboards. Chris Curry will continue his role as industry principal and will be maintaining the link and collaboration between industry and the program.

To quickly cover the agenda, I will provide the pensions dashboards program update, touching on the standards, preparations for connection, our engagement activities with industry, the pensions dashboards advisory group, and a bit on user testing. Then we'll go over to John, who will talk about the DWP connection guidance and the staged timetable, and You Yuwill talk about the regulator's approach to compliance. There will then be some time for Q&A at the end.

On standards, the pension schemes act 2021 and the pensions dashboards regulations give authority to PDP, as part of MAPS, to set standards. These relate to the practical operations of pensions dashboard services and the digital infrastructure needed to support them. Standards to support connection include data standards, technical standards, reporting, and the code of connection, which includes service operational and security standards. Since we previously published versions of the standards, there has been extensive engagement with industry on the data standards, and the feedback has been invaluable. We continue to work on finalizing updated versions of these standards to support connection testing later this year and then the wider industry staging.

Having shared the updated data standards with our volunteer participants at the end of March, we received further comments, which are currently being worked through before we can publish this document. We expect to do this in the coming weeks. We will also look to publish updated versions of other standards, including the code of connection, over the coming months once they have been tested and validated with our volunteer participants.

There are also design standards that dashboard service firms will need to abide by, which will sit alongside and complement the FCA's regulatory framework for pensions dashboard services. The government recently amended the regulated activities order to bring the new activity of operating a pensions dashboard service within FCA regulation. At the end of March, FCA published a further consultation on the regulatory framework for pensions dashboard service firms, which runs until the 8th of May. Once the FCA has considered feedback on this and the original consultation, it will finalize a full set of rules and guidance for pensions dashboard service firms, following a commitment to provide at least 12 months' notice ahead of the first connect-by dates.

In guidance, DWP recently published the staged timetable ahead of the first connect-by date at the end of April 2025, and as I've said, more on that is to follow. We anticipate that pension providers and schemes will connect to the ecosystem through their administrator or an integrated service provider (ISP) that they or their administrator has chosen for them. For those building a direct route to connection, we are preparing to start connection testing with them later this year, which will help to support wider industry onboarding of schemes and providers in line with the DWP stage timetabling guidance. Pension providers and schemes building their own connection who have not engaged with the program need to contact us at the earliest opportunity to discuss their connection plans. There is an email on the slide there to get in touch with us.

With schemes and providers preparing to connect, the pensions regulator has published comprehensive guidance outlining the requirements and has more recently made available a downloadable checklist that breaks down the essential tasks schemes need to stay on track. Following the publication of DWP's guidance, TPR will be contacting all schemes at least 12 months ahead of the connect-by date and guide them on necessary actions to prepare. In July, the FCA revised its pensions dashboard rules for FCA-regulated pensions providers to align with the new 31st of October 2026 deadline that is in the government's regulations. Complementary to information provided by the DWP and regulators, PASA has published helpful practical guidance on what it means for a scheme to be connection-ready and the steps towards achieving that.

Working with our volunteer participants on connection testing later this year, we are developing guidance for them and the wider industry that will support connection, including details around how and when schemes should make contact with the program. This will be made available on our website later this year, where you will be able to access a range of FAQs, and where necessary, you can raise a query. In most cases, you should discuss your plans for connection with your administrator or ISP in the first instance. Our group of over 20 volunteer participants, made up of pension providers and schemes, third-party administrators, and ISPs, will begin connection testing later this year in order to be ready for the wider industry connection dates in guidance.

As connection progresses, PDP will work with industry to further refine processes and ensure connection is as smooth as possible. It's important to the success of the program to maximize our engagement with industry to share updates on our progress and to hear your feedback and comments. Chris Curry and others from the program regularly give presentations and speak at panel discussions at various external events to raise awareness of the program, share the latest updates, and field any questions. In total, we've attended 17 events since November last year. Recently, for example, some of these events have included the professional pensions admin and data forum, the PMI’s DB conference, and a private and public pension summit hosted by DG Publishing. We've also participated in a number of external webinars arranged by external organizations and are happy to support these for others. In addition, we will continue to run our regular PDP webinars such as this one. You can find all our previous webinar recordings, slides, and Q&As on the PDP website. Going forward, PDP will run webinars, discussion fora, and other online events on important program milestones or topics to support preparation for connection.

We continue to work collaboratively with DWP, regulators, and industry across a range of areas to deliver dashboards. We lead a range of groups and fora to support industry and to gain their input on dashboards to shape connection processes and guidance. These include a connection forum, a dashboards forum, and discussion fora. All of these are open to anyone to join. We also support and collaborate with industry through various more targeted working groups. This includes a connection delivery group which comprises our cohort of volunteer participants to look at testing and refining processes and solutions for connection. We also have a communications working group with representatives from across industry working in communications, engagement, and PR. We will set up a connection working group for potential dashboard providers at a later date, once the FCA's regulatory framework for dashboard providers has been finalized.

PDP also attends a number of industry, government, and regulatory groups such as the ABI dashboard working group, PASA's dashboard working group, the software providers group, and on occasion, we attend the TPR's third-party administrators forum and a joint industry forum led by the Society of Pension Professionals. In addition, we meet regularly with DWP and the regulators to share and coordinate our communication and engagement plans. They help us to gain valuable insights and hear a range of perspectives from different parts of the industry, which helps to inform our activities. The pensions dashboards advisory group, which replaces PDP's steering group, provides input on a range of issues that are important for the success of the program. The group's existing membership includes all the previous members of the steering group, and eight new members have been appointed. Members are tasked with providing insights to shape the delivery of dashboards and input on emerging operational and delivery topics and other issues that are relevant to the success of the program. The new members represent a range of organizations involved in the different stages of delivering dashboards, including pension providers and schemes, administrators, and ISPs. We will also be setting up a consultant subgroup which includes some of the applicants to the advisory group.

We continue to publish updates and informative articles on our website. Recently, these have included a look back at the progress made in 2023, a guide to the central digital architecture, and an overview of how PDP is engaging with industry. We have also released a number of blog posts addressing some of the more common queries that have come up on topics including standards, testing, and the dashboards available point. You can find all of our previous blogs and news articles on the PDP website under the publications tab. We have also provided guest blog posts and articles for a number of industry publications and websites. You can follow us on LinkedIn and Twitter (or X) to keep updated with our publications. We continue to send out regular email newsletters to provide program updates and answers to frequently asked questions. You can find our previous FAQs newsletters on the website, and over the next few months, we will publish newsletters, blogs, and articles on important program milestones and publications. You can sign up for all of this via the website, and there'll be links at the end of the presentation.

In terms of user testing, once the first pension providers and schemes are connected to the live dashboards ecosystem, PDP will be undertaking user testing with individuals using the service to see data about their pensions. This is crucial to ensure that the end-to-end user experience of the service is working well and that the service meets users' needs. We expect this type of testing will start with small numbers but can also be carried out at scale and provide insights on, for example, user behavior and the success of data matching. This user testing will also inform the Secretary of State's decision-making around the date that the service should be launched to the public, the dashboards available point (or DAP). PDP intends to convene a user testing and planning group involving industry representatives to help us develop and coordinate plans for user testing of the live service once industry staging has begun. This could include defining testing requirements and the activities involved, how users will be invited to participate in testing the service in a controlled environment, volumes of users, and how insights from this testing will be gathered and reported on. We've been having exploratory conversations with individuals with different backgrounds and skill sets from various organizations who are interested in getting involved with user testing. We're pleased to see the enormous enthusiasm for collaborating in this later phase of testing from such a variety of stakeholders. We will involve industry stakeholders and convene a working group once we have further developed our internal plans and goals for user testing in that later phase.

Meanwhile, within PDP and MAPS, there is research and testing already underway to inform the initial design and build of the MoneyHelper dashboard, as well as other aspects of the user journey such as find and ID. MAPS is conducting research involving a wide range of users to test the accessibility and understandability of the proposed solution. This will ensure that the MoneyHelper pensions dashboard will securely meet the varying needs of all dashboards customers, including those with access requirements and varied digital skill levels. The dashboard will integrate into MoneyHelper's existing pensions and retirement guidance to help people make informed decisions for later life. This service will be underpinned by a digitally enabled customer support model, which is currently in design. As with other dashboards, the MoneyHelper pensions dashboard will securely connect to PDP's central digital architecture and align with PDP standards. The MoneyHelper project team is working closely with PDP to ensure the MoneyHelper pensions dashboard is ready for testing with pensions providers at the earliest opportunity. From this current research and testing, we expect to generate a clearer sense of priorities for testing in later phases, which will then inform our approach to wider industry collaboration, including when and how to configure a user testing and planning group.

That's enough from me. I'm now going to hand over to John Higgins from DWP to take you through their guidance.

Thank you, Joe, and good afternoon, everyone. My name is John Higgins, and I'm from DWP's pensions dashboards policy team. I'm going to be providing a brief overview of DWP's guidance on the staged timetable for connection, which was published on the 25th of March, including how this will support industry and explain industry's role in enabling the success of pensions dashboards.

Before diving into the purpose of the guidance, it may help to provide some context and background. Attendees on this call may already be familiar with the term staging, but for the avoidance of doubt, this relates to a phased approach to connecting different categories of relevant pension schemes and providers to the digital architecture built by the PDP. The rationale for adopting a staged approach to connection was to maximize coverage of pension schemes and providers on pensions dashboards over a timescale that was deliverable for industry, the regulators, and the program. This approach was subject to significant industry engagement, including the PDP's own call for input on staging, and DWP also had a number of other public consultations.

Our main priority is to be able to launch dashboards at the earliest opportunity while at the same time considering the industry's ability to connect. In 2022, DWP's pensions dashboards regulations included a staging profile which set out dates by which large and medium schemes had to connect to the digital architecture. However, following the reset announced last March, a revised approach was needed to connecting schemes. Amending regulations came into force last August, which removed the mandatory staging profile from the 2022 regulations and introduced a single connection deadline of 31st of October 2026 for relevant occupational pension schemes. This change was replicated by the Financial Conduct Authority in their handbook rules for personal and stakeholder pension providers. DWP, with input from its delivery partners, engaged with various industry groups during November and December last year on a draft connection timetable to be issued in guidance. After considering feedback, we were able to officially publish the guidance on the 25th of March.

Fundamentally, the timetable in guidance retains the phased approach to connecting pension schemes and providers to the digital architecture. The timetable contains different connect-by dates for 16 cohorts of large and medium schemes and providers running from the 30th of April 2025 until the end of November 2025 for large cohorts and then from January 2026 until September 2026 for medium schemes. All schemes and providers in scope must be connected by the 31st of October 2026. There are two breaks in the first part of the timetable where there are no connect-by dates in July and December 2025. During our engagement with industry last year, we had proposed a three-month buffer at the end of the profile. However, after considering industry feedback on the need to consider peak annual leave seasons in summer and winter during the first part of the timetable, we changed the positioning of the breaks accordingly. The change also allows a possibility for delayed connections from the initial cohorts to be picked up during these periods. I would, however, encourage anyone planning to deviate from the published timetable to discuss their plans with the PDP and the relevant regulator.

Rather than listing every connect-by date in the guidance, the table on the slide provides an extract from the timetable with some of the key milestones for when schemes are being encouraged to connect. We expect the largest master trusts to be connected by the end of April 2025, the largest DB schemes to be connected by the end of May 2025, and public service pension schemes at the end of October 2025. Then we have a longer tail of schemes we've described as medium-sized, connecting between January 2026 and September 2026. Of course, you can see the complete timetable in the guidance published on gov.uk.

One of the benefits of retaining this staggered approach to connection is that it will help to manage the flow of connections for around 3,000 pension schemes and providers to the dashboards ecosystem. In addition, the timetable still prioritizes the connection of the largest schemes and providers to ensure the widest coverage for consumers at the earliest opportunity. If industry follows the timetable in guidance, this will help enable the program to undertake user testing at scale and at pace. In turn, this will help to inform the safe and secure launch of pensions dashboard services for use by the public at the earliest possible point.

As I've said previously, all schemes and providers in scope are legally required to be connected to the pensions dashboards ecosystem and be ready to respond to requests for pensions information by the 31st of October 2026 at the latest. As such, industry must continue to prepare their data ahead of the wider industry onboarding, which is expected to start in early 2025. Trustees or managers and pension scheme providers connecting close to the connection deadline could place undue strain on all parties involved in facilitating connection, including PDP, administrators, and integrated service providers. Where trustees or managers and pension scheme providers connect later than their connect-by date in guidance, they do so at greater risk of not being connected by the connection deadline in legislation. It will also be important to take note of any guidance from the pensions regulator or the PDP about the expected timescales for completing connection and to engage early with your administrator or ISP to achieve this.

Those with keen eyes will have noticed the timetable in guidance is somewhat shorter than our original staging profile which was set out in the regulations. We believe this is achievable because we know a lot more now from our engagement about how industry as a whole is planning for connection. When we first set out the staging profile in regulations, we had limited information about the number of schemes and providers expected to build a direct connection to dashboards. We now expect the vast majority of schemes to connect via an ISP or their administrator, which helps to streamline the process. As was mentioned earlier, if you are expecting to build a direct connection and you haven't done so already, you should contact PDP at the earliest opportunity to discuss this because it will be a more involved process requiring significant technical expertise.

Whilst the timetable is not mandatory, given that it has been published to ease the connection journey, DWP encourages trustees or managers and pension scheme providers to follow the dates in this guidance unless there are exceptional circumstances which prevent them from doing so. We hope the connection guidance provides further support for industry to prepare ahead of connection and we look forward to maintaining close collaboration between our delivery partners and wider industry on this important project. With that, I'll hand over to You Yufrom the pensions regulator.

Thank you, John, and good afternoon, everyone. My name is You Yu, and I'm the policy delivery lead at the pensions regulator. Following the publication of the DWP guidance, we have also updated our guidance on when your scheme needs to connect with the dashboard section. On this page, we introduce a check-in tool which allows schemes to check the connect-by date according to your scheme's type and size of relevant members at the reference date, which is the scheme year between 1st April 2023 and 31st March 2024.

We have set up our expectations in our guidance that trustees and scheme managers should check when their connect-by date is, read the DWP guidance, and take the guidance into account when making decisions around the connection. It is important to emphasize that trustees and scheme managers should have adequate governance and processes in place to support your decision-making as required in our code of practice. Trustees and scheme managers are accountable for the decisions that are made and therefore should ensure that they have access to all the relevant information before acting. A key element to consider when making this decision is what the practical delivery plan looks like for your scheme according to your scheme's specific situation. Therefore, we advise you to talk to your advisers and the parties that support you, such as ISP providers, software providers, and actuaries, to agree with them what is required and then make sure that actions are taken accordingly in a timely manner. Adequate governance and controls to ensure that the work is progressed as planned is also very important.

As John mentioned in his explanation when he introduced the DWP guidance, the connection timetable has been published to ease the connection journey. Therefore, we expect schemes to follow the connect-by dates that are set out in the guidance. It's critical for schemes to be aware that not following the guidance could expose you to a greater risk of not being able to comply with your dashboard duties. For example, it is possible that you may be unable to connect to the dashboard by the legislative connection deadline, which is 31st October 2026, due to limited capacity in the industry or with PDP.

When trustees and scheme managers make decisions around connection, there is a need to consider the balance of those risks and whether any potential breaches are material and significant to TPR. Trustees and scheme managers will need to be able to demonstrate upon request how they have had regard to this guidance on connection. Therefore, it is also important to keep an adequate audit trail for any key decisions, the associated risks, and any mitigation actions. Many schemes that we engage with are also actively maintaining a decision log for dashboards, which is good practice.

We are currently in the process of updating our compliance and enforcement policy and looking to publish our final policy together with our consultation response this summer. The principles and general enforcement approach published in our draft policy are not changing. We will be pragmatic with our approach but will be robust when we see intentional non-compliance. We recognize that delivering pensions dashboards is a huge challenge for the industry. We will work with the industry as issues arise and use our powers fairly and proportionately, looking at the particular circumstances of each case. We aim to maximize compliance with duties so that savers can get a full and accurate picture of their pensions as soon as possible.

I'm now handing back to John to lead our Q&A section.

Thank you, You Yu. This slide is giving you a link to some useful resources, and we will share these slides that will be made available on the website. You'll be able to access those directly. We will now move on to the questions. Please add any further questions that you may have.

One of the questions we've had is: are many funds choosing to have a direct connection rather than an ISP? I'll pick that up. It is the case that some providers have chosen to have a direct connection, and they are among our volunteer participant cohort. I'm aware of potentially some others, but it's a small number at the moment who are planning a direct connection. We do expect that the vast majority of pension providers and schemes will connect to the ecosystem either through their administrator or an ISP, and a lot of administrators will be connecting through an ISP as well. This is borne out, I understand, by TPR's analysis. As we mentioned, if anybody is planning to connect directly to the ecosystem and hasn't been in touch with us, then please do contact us at the support PDP mailbox.

We had a question that I think I'll put to John in the first instance. The connection guidance has a connect-by expectation. As this is guidance, must we meet these dates?

It's not mandatory to connect by the dates in guidance; it is guidance. However, there is a requirement in the regulations that you must have regard to the guidance. The approach of having the connect-by dates in guidance does provide some flexibility, which may be utilized by administrators if they have a large book of schemes all connecting close together. Spreading out over a couple of months rather than doing it all in one month is the kind of thing we envision where that might happen. But we do recommend that you follow it. As said in the presentation, if you don't, you're putting yourself at risk of finding that there are lots of other schemes trying to connect later, and the ISPs or your administrator may not have capacity to do it, and therefore you put yourself at risk of missing that connection deadline, which would also be a breach of the regulations.

You Yu, do you want to say anything further on that?

Yes, I would echo what John said. Not following the dates in the guidance will expose schemes to a greater risk of not being able to connect by the legal deadline. Although we understand that some schemes may be unable to meet the connect-by date due to specific situations, such as a planned change in administration or a buyout, we expect schemes to discuss their intentions with their administrator and ISP in the first instance and also approach PDP regarding their plans. As TPR, we take a pragmatic approach, but if there is intentional non-compliance, that is significant to us.

Thank you, You Yuand John.

We had another question about data standards: there was an expectation that data standards would be released around Easter. Can we please have a commitment to delivery as they are holding us back from the build?

Yes, we shared the updated data standards with volunteer participants ahead of publication and intended to publish shortly thereafter. We received some comments back identifying some inconsistencies between the data standards and the JSON schema that were also shared. We need to work through those, but it shouldn't take us long. Once we've worked through those and gone through our internal governance to get those changes approved, we will then be in a position to publish the data standards. It's a matter of weeks, not months.

There's another one here, You Yu, about orphan schemes. Where schemes are orphaned from their trustees, what can the TPR do to help us identify trustees where we have lost contact with them?

Thank you, John. Yes, orphan schemes are on our radar. We have received comments around orphan schemes through our compliance and enforcement policy consultations. We aim to publish our response regarding orphan schemes in our consultation response. Currently, we are still looking at the scale of the problem. Most of these orphan schemes are not in scope for dashboards yet, but we are still trying to establish the size of the problem and see what support TPR can provide to support the schemes and the administrators.

Thank you, You Yu. We have another one here: can you confirm when state pension details will be made available on the dashboard?

I can say that we are working with the DWP state pension team on preparing to involve them in connection testing later this year, and we are working to ensure that DWP state pension data will be available at the first iteration of the dashboard. John, do you want to add anything more about that?

We are committed to making sure that state pension data will be available from the first launch to the public. We expect it to be among the first organizations to be connected and to be involved in connection testing.

Thank you. Another one for me: the pensions regulator guidance says schemes will need to register with MAPS. How is this done?

Registration with MAPS is also a requirement under the regulations and in FCA rules. This is done as part of our connection process. For providers and schemes connecting via a third party, registration will be managed by that third party.

There is a question about the pros and cons of a direct connection as opposed to an ISP. I think this is one for schemes to consider with their administrators and have that conversation, but we can take this away and get some thoughts from colleagues in the industry.

When will more information on the program timeline be published?

We are working closely with organizations building a route to connection on delivery milestones, which will include the conformance and compliance testing strategy. Anyone considering building a route to connection should get in touch with the program. We will be publishing updates through our website to keep people informed of progress, and we will also have a progress update report coming out in the next couple of weeks.

I think there are not many questions coming in now, so this may be an opportunity to give people 15 minutes of their time back. With no more questions coming in, I will bring this to a close. Thank you to our speakers, John Higgins from DWP and You Yu from TPR, and also to the team here, Sophie and others, who have helped organize this webinar. As I mentioned, we will be publishing our progress update report soon, so do look out for that and further information on our website. Have a good afternoon.