Private Sector Dashboards Working Group: Proposal response

Summary

1. As part of its commitment to enabling the connection and future operation of private sector dashboards (PSDs), the Money and Pensions Service (MaPS) recently sought views from industry about how the industry participant group, which facilitates close collaboration between MaPS and those organisations connecting to the central digital architecture (CDA) as or on behalf of pension providers and schemes, can be adapted to support our work in delivering PSDs.

2. We are grateful to all those who responded. This note provides an overview of the feedback received and sets out our plans for engaging industry. We are now inviting those organisations which consider themselves eligible to join a working group to apply.

Industry feedback and our response

3. A total of 36 responses were received. Respondents were overwhelmingly supportive of the proposal to set up a working group:

• 27 respondents agreed with the proposal
• 8 respondents partially agreed
• 1 respondent disagreed

4. Those who agreed (either fully or partially) with the proposal highlighted a number of potential benefits:

• Collaboration across industry: Many respondents noted the value of collaboration both for industry and MaPS. They noted that it had the potential to enable quicker progress and develop more grounded/real-world solutions; generate feedback loops with MaPS and the regulators (the Financial Conduct Authority (FCA) and The Pensions Regulator (TPR)); and provide the opportunity to support industry to quickly and efficiently resolve issues, such as interpretation of standards or in relation to technical matters.
• Proven success of the existing voluntary/participant model: Some respondents highlighted that the existing approach worked well for the connection of pension providers and schemes and those connecting on their behalf, and should be replicated for dashboard providers.
• Support for better consumer outcomes: Joint working is seen as essential to delivering good user journeys, consistent data presentation, and overall trust in dashboards.

5. Those who did not agree with the proposal, or who expressed qualified agreement, cited the following concerns:

• Lack of clarity on timelines: Without a clear roadmap or launch date, some were concerned that firms cannot justify committing resources or funding, or might not yet be able to meaningfully engage.
• Risk of over-large or unfocused group: There were some concerns that unclear membership criteria could lead to too many participants, reducing the effectiveness of the group. On the other hand, there were concerns expressed that too narrow a membership could exclude valuable stakeholders such as data providers, who have a keen interest in progress and, for example, how data is displayed.
• Commercial sensitivities may impact the effectiveness of the group: Respondents expected firms to be cautious about sharing plans and innovation with competitors, which could constrain meaningful discussion, and noted that the commercial context is different to that of those connecting on behalf of pension providers and schemes.
• Uncertainty about the purpose and scope of the group: Some felt the remit risks being too wide or drifting into areas (for example, policy, design, or commercial models) that could slow delivery, suggesting a tighter, delivery-focused scope is needed.
• Dependency on PDP delivery pace: There were some concerns about whether the group would be able to progress work efficiently given the dependency on PDP to be able to deliver the standards and other artefacts.

6. Given the strong overall support from respondents, PDP intends to go ahead with setting up a working group. We wish to begin this as soon as possible to help the development work get underway as early as possible. The instructions below set out how organisations can apply to join the working group.

7. Nevertheless, feedback has been helpful in highlighting areas which need to be addressed, both as part of the terms of reference for the group, and for the engagement strategy more broadly.

8. We acknowledge concerns that a lack of clarity on timelines can make it harder for firms to commit resources to a working group. MaPS is committed to delivering the means by which PSDs can connect and operate, but the launch of PSDs rests on a number of dependencies, some of which are external to PDP. This means that it is not yet possible to set out a defined timetable for launch. .

9. MaPS expects the MoneyHelper Pensions Dashboard (MHPD) to be available to the public in financial year 2027/28. An update on MHPD launch plans will be provided around the time of the 31 October 2026 connection deadline, when significantly more user testing will have been undertaken. The MHPD launch date will be decided by the Secretary of State for Work and Pensions, informed by the findings from ongoing consumer testing of the MHPD, among other things. The written ministerial statement of October 2024 noted the opportunity for learning ahead of the launch of PSDs, with the duration and shape of this learning yet to be finalised.

10. While it is currently unavoidable, we acknowledge the difficulties that this uncertainty causes for prospective dashboard operators in securing resource, but we also recognise that setting expectations that have a high degree of uncertainty is more disruptive and costly, if those expectations cannot ultimately be met.

11. We therefore want to be very clear with prospective group members that, while we are very keen to have the support of an industry working group as we develop the means to connect and operate PSDs, and would encourage all those organisations who are able to participate to do so, this must only be in the context and knowledge of this timeline uncertainty. Given that there is significant complexity in the overall delivery landscape, there may also be periods of lower activity during the operation of the group, where other work takes precedence. None of this should be read as implying any uncertainty about MaPS’ and Government’s commitment to PSDs, which has been reiterated by both MaPS and the Minister for Pensions.

12. We are keen to stress that participation in the group is not a pre-requisite to becoming a dashboard operator, and neither does it confer any regulatory status. We will ensure that those outside the working group are kept appraised of progress . Relevant documentation and other artefacts will be shared as soon as we are able, including via formal consultation where appropriate.

13. Some respondents noted that the group had the potential to be too narrow, excluding the potential for others to support on, for example, iterations of design standards, which have wider interest. We agree, and although we think a reasonably focused working group is the most effective way of making progress, we will maintain contact with a range of other stakeholders with a view to engaging them on specific subjects, as well, as mentioned previously, as ensuring wider communication of progress.

14. Confidentiality was raised as a potential issue for some. We agree that commercial interests need to be sensitively managed, and that commercial sensitivities might inhibit information sharing. We do not believe a multi-lateral non-disclosure agreement is likely to be an effective way of mitigating risk. Instead, we encourage participants to consider whether information they might share is commercially sensitive and whether it is therefore suitable to share with other participants. MaPS is happy to facilitate one-to-one conversations to support information sharing in these cases and will respect the confidentiality of any information provided.

15. To support the operation of the group, we ask that participants sign a framework agreement. This is likely to set out a number of principles around confidentiality, as well as collaboration, ways of working and responsibilities; facilitation of testing; and access to the ecosystem. We will provide a draft of the framework agreement to the group and provide the opportunity for feedback.

16. Finally, a concern was raised about the potential for this group to stray into areas beyond its remit, including matters of policy. We are clear that this group is a working group focused on developing the technical and practical aspects of the means by which PSDs will connect and operate, and the group chair will endeavour to maintain this focus. The group’s remit is not intended to cover the frameworks and obligations set out in DWP’s regulations and FCA’s rules, both of which have been consulted on previously and can be considered as settled.

17. A draft terms of reference is available below.

Applying for your organisation to join the working group

18. We are now accepting applications from organisations who wish to be part of the group and who consider that they meet the selection criteria, as set out in the terms of reference. Those criteria are as follows:

Members will be from organisations which are actively planning to operate a private sector dashboard, either independently or in partnership, or who plan to play a material role in enabling the delivery of a dashboard as a technology supplier. This is expected to include:

• Prospective dashboard operators.
• Technology and service providers.

19. It is unlikely that those parties who have broader interests in PSDs, but who are not playing an active and material role in delivering a PSD, will be considered suitable as members of the group.

20. Members will be expected to support the work of the group as set out in the objectives and scope section of the terms of reference, and perform the tasks documented in Appendix 1. This means the party should have suitably qualified resource available to undertake this work.

21. Prospective members should read the terms of reference and ensure that they meet the membership criteria and understand the scope of the group.

22. Those who wish to submit an application should do so by completing the application form by 18 June.

23. MaPS will consider applications and may contact organisations for further information to support our decision-making. We may decline applications where we consider that the applicant does not meet the membership criteria. Those organisations which are not yet in a position to join the group now may apply at a later date, at the discretion of MaPS.

Terms of reference

Purpose

1. This terms of reference sets out how the Private Sector Dashboards Working Group will be convened and run, its purpose, and its membership.

Audience

2. Working group members and prospective members; the Pensions Dashboards Programme (PDP) / the Money and Pensions Service (MaPS); the Department for Work and Pensions (DWP) and the Financial Conduct Authority (FCA).

Background

3. Pensions dashboards seek to help people engage with their retirement planning by enabling them to see their pensions information, including their State Pension, in one place online.

4. MaPS is responsible for the delivery of the central digital architecture (CDA) and for the publication of the various standards and other requirements to which ecosystem participants will need to adhere in order to connect and operate.

5. The MoneyHelper Pensions Dashboard (MHPD), also delivered by MaPS, will be launched first, after which Government intends for other organisations to also be able to operate private sector dashboards (PSDs).

6. MaPS has started to develop the systems, processes and documentation necessary to facilitate the connection, launch and operation of PSDs, and sought views on proposals to convene an industry group to support this, building on the model used to support the facilitation of pension providers and schemes in fulfilling their legislative duties relating to pensions dashboards.

7. This terms of reference sets out the framework within which the new Private Sector Dashboards Working Group will operate, including its objectives, scope and duration; membership and selection criteria; ways of working; and governance.

Objectives and scope

8. The working group will:

• Facilitate collaboration between MaPS and prospective dashboard operators and their suppliers.
• Support the development of the processes, standards and guidance for private sector dashboards which will facilitate connection and operation.
• Enable testing, iteration and validation of dashboard-related processes and functions both for MaPS and for prospective PSD operators and their suppliers.
• Create a regular opportunity to connect on updates, communications and engagement delivery.

9. Further detail on likely activities is set out in the appendix.

10. Areas outside the scope of the group’s remit include, but are not limited to:

• Prospective PSDs’ progress through the connection journey itself.
• Support during the operation of pensions dashboards.
• Communications and engagement relating to other aspects of partners’ operations, unless this impacts on private sector dashboards.
• Debate about the frameworks and obligations set out in DWP’s regulations and FCA’s rules, both of which have been consulted on previously and can be considered as settled.

11. The working group is advisory in nature. Where the group supports MaPS in producing the artefacts necessary to facilitate PSDs, consensus will be sought where possible, but final decisions and ownership of those artefacts will remain with MaPS.

12. The scope of the group may change over time, with the agreement of members.

Duration

13. The working group will operate for as long as is required to support the development of the processes, standards and guidance for private sector dashboards which will facilitate connection and operation.

Membership and selection criteria

14. Membership will be drawn from organisations which are actively planning to operate a private sector dashboard, either independently or in partnership, or who plan to play a material role in enabling the delivery of a dashboard as a technology supplier.

15. The working group is therefore expected to include:

• Prospective dashboard operators.
• Technology and service providers.

16. Representatives from MaPS will participate, as will its contractors, and relevant stakeholders (such as FCA, DWP), as appropriate.

17. It is unlikely that those parties who have broader interests in PSDs, but who are not playing an active and material role in delivering a PSD, will be considered suitable as members of the group. Members will be expected to support the work of the group as set out in the objectives and scope section of this document, and perform the tasks documented in appendix 1. This means that the party should have suitably qualified resource available to undertake this work.

18. These selection criteria for the group are not intended to match the likely criteria which an organisation would need to meet to connect to the CDA and become a dashboard operator.

19. The following principles apply to membership and participation:

• Membership is voluntary.
• Membership is not a prerequisite for becoming a dashboard operator.
• Membership does not represent a necessary part of the connection journey and does not confer any regulatory status or approval.

Invitation, application and consideration, and new members

20. MaPS will manage the group’s membership to ensure that the composition reflects the criteria set out in this terms of reference. Prospective members will be invited to submit an application pro-forma to MaPS for consideration against the criteria and with a view to ensuring that the group is of a workable size. Those who are not considered to be suitable from the outset may wish to consider being part of a wider interest group to maintain contact with progress on PSDs.

21. New members may be admitted later at the discretion of MaPS.

Ways of working

22. The working group will:

• Operate collaboratively and iteratively.
• Share insights, data and feedback openly within agreed confidentiality constraints.
• Provide timely input into MaPS deliverables and milestones.
• Engage in structured workshops, testing cycles and review sessions.

23. Meetings will be held monthly at an agreed frequency. Meetings will be virtual or face-to-face in London, as appropriate and with the agreement of the group. Communication will also take place via email as appropriate. Given that there is significant complexity in the the overall delivery landscape, there may also be periods of higher and lower activity during the operation of the group. MaPS will endeavour to be transparent about this to support resource planning.

24. MaPS may engage sub-sets of the working group from time to time, for the purpose of, for example:

• Expediency.
• Sharing preliminary thinking or drafts before coming to the wider group.
• Covering topics relevant to some rather than all parties, or where particular expertise sits with a particular group.
• Maintaining commercial confidentiality.

25. MaPS will be responsible for organising and chairing meetings and circulating agendas. Individual members are responsible for proposing items for discussion up to 3 working days before the meeting. Papers will not normally be required, however, the chair reserves the right to postpone discussion of an item if they believe a paper would be more appropriate to enable a proper discussion.

Governance, framework agreements and confidentiality

26. A number of steps are taken to support the work of the group:

Framework agreement

27. Members will be asked to enter into a framework agreement with MaPS. This is a bi-lateral agreement between each provider and MaPS (and not between each provider) which is likely to set out a number of principles around confidentiality; collaboration, ways of working and responsibilities; facilitation of testing; and access to the ecosystem.

Confidentiality

28. The operation of this group gives rise to potential commercial sensitivities between parties. MaPS has not sought to require working group participants to sign up to a multi-lateral non-disclosure agreement since this is not considered to be an effective mitigation. Members are asked to participate in group discussions respectfully of others’ confidences, and should take care to withhold any information that they consider to be commercially sensitive.

29. MaPS will support this by issuing periodic reminders, and, where helpful, engaging with parties on a one-to-one basis to facilitate the provision of feedback which might otherwise represent a risk to commercially sensitive information.

30. MaPS will ensure that confidentiality is maintained in any of its outputs, both verbal and written.

Appendix 1: key tasks

• Support the development of processes and requirements for private sector dashboards, including the review, testing and refinement of drafts of relevant standards. This will include design standards, which are exclusive to PSDs, and security, technical, connection and reporting standards, including API specifications.
• Enable industry to provide expertise and feedback to inform MaPS delivery decisions.
• Allow MaPS and industry to collaborate on the development of guidance that explains processes and requirements.
• Enable potential PSD operators and their suppliers to engage in early-stage testing, iteration and validation.
• Support MaPS as it ensures that the CDA includes all the necessary functionality to support multiple dashboards.
• Support development of the process of PSD connection, including the incorporation of new stages such as user testing and the third-party audit, and interactions with the FCA’s authorisation process.
• Provide support on interpretation of data and design standards and sharing of best practice.
• Help MaPS understand and develop the support model needed for PSD operators.
• Help MaPS understand and incorporate any necessary changes to the support model for dashboard users.
• Ensure that industry is closely involved with progress in the programme to support its own business planning.
• Develop the approach to user testing of PSDs, including the potential use of synthetic and real user data.
• Support end-to-end testing of dashboard journeys which include PSDs.
• Provide a structure for sharing upcoming communications and engagement activity and enable partners to provide input into proposals, language and timings.
• Create a regular opportunity to connect on updates, communications and engagement delivery.