Reporting standards consultation outcome

Introduction

The Pensions Dashboards Programme (PDP) (part of the Money and Pensions Service (MaPS)) consulted on proposals to update the reporting standards to implement routine daily reporting of data to MaPS via API. An API is an application programming interface – a set of rules and protocols that enables different software applications to communicate with each other.

The reporting standards set out requirements on pension providers and schemes for generating and recording operational information and reporting it to MaPS on a regular basis. The information will support the oversight and management of the dashboards ecosystem and compliance monitoring and enforcement.

The current reporting standards, published in March 2025, and therefore currently in force, require only the generation and retention of records for the data requirements specified, and that these records must be made available to MaPS on request. However, the publication made clear MaPS’ intention to implement (at a later date) routine reporting of this information to MaPS via API, and indicated the expected frequency for this (daily). Our intention to move to daily reporting via API had been stated in previous publications, including in our 2022 consultation on draft standards.

In the consultation, we set out the high-level testing requirements and our intended implementation approach. We set out that connected parties would need to undergo a structured process of testing and assurance activities, in sequence, before commencing submission of reporting data on a daily basis, ahead of a mandatory implementation deadline. We proposed a mandatory deadline of 30 November 2026 for all parties to have implemented daily reporting.

The consultation on the proposed approach to implementation of daily reporting and the proposed mandatory deadline was launched on 28 January 2026 and closed (following an extension) on 30 April 2026.

We received responses from a range of stakeholders, including directly-connecting pension providers and schemes, third-party administrators, and third-party connection providers who provide the means through which client pension providers and schemes and administrators connect to the ecosystem.

We are grateful to all respondents for their feedback and have carefully considered the comments received, together with our delivery partners at The Pensions Regulator (TPR), the Financial Conduct Authority (FCA) and Department for Work and Pensions (DWP).

This paper summarises the feedback received, provides our response, and confirms our intended final mandatory implementation deadline, subject to approval by the Secretary of State for Work and Pensions and the Department for Communities (Northern Ireland).

Questions and feedback received

Question 1

Responses to this question indicated mixed levels of confidence in the deliverability of implementation by the proposed deadline. Some respondents agreed that the proposed implementation date was deliverable, provided that MaPS is able to provide testing materials and implementation processes in a timely fashion, confirm technical specifications and avoid late changes, and provide timely support to organisations through the implementation process.

However, some respondents expressed lower confidence in their ability to meet the proposed deadline and some disagreed that the proposed deadline was deliverable. These respondents expressed significant concerns that the proposed timeframe for industry building, testing, and assurance was very compressed, leaving little room for any issues that may arise through the journey causing delays. As well as this potential lack of contingency, respondents were concerned that the lack of clarity on the testing and implementation process and timing could mean that implementation might not be completed by the proposed deadline.

Across the board, responses highlighted the dependencies on MaPS in terms of timely availability of stable technical and testing information and materials as well as capacity to support directly connecting organisations through the testing and assurance process. Dependencies from MaPS cited for industry’s implementation included:

• provision of a detailed implementation schedule and process flow, including the detailed implementation steps from initial testing to assurance and full live production, together with their expected time durations and details of the number of parties that may go through implementation processes concurrently
• timely delivery of the reporting API
• timely delivery of the test harness (this has since been made available), test packs and test environment
• confirmation of stable technical specification and ensuring there are not late changes
• sufficient availability of the testing environment to support parties to undergo integration testing (responses expressed concern around the risk of access to the test environment for integration testing being a bottleneck)

A large membership organisation also highlighted the dependency of pension providers and schemes on the directly connecting organisations and concern that delays at the directly connecting organisation level could affect some of the market. It anticipated that while some members may be able to meet the proposed deadline, it would be unlikely to be universally met. It highlighted that industry is already delivering other major initiatives in parallel, such as the Value for Money framework, targeted support and simplified advice, which increases delivery risk and constrains available technical and operational capacity.

Question 2

Some respondents did not identify any challenges. Others identified several challenges. The main challenges identified were:

1. The need for stable technical specifications and the risk of late changes to technical specifications causing delays to implementation.
2. The uncertainty around the implementation and expected durations for each step. However, the experience of initial connection of directly connecting organisations over 2025 and 2026 suggests that expected durations will be very difficult to estimate, given the wide ranges in times taken per stage across the organisations.
3. Capacity constraints in the integration testing process and staggered testing windows, given that MaPS cannot support all directly connecting organisations simultaneously within the testing environment.
4. The need for further details on test content and requirements to inform implementation plans.
5. The risk of changes to the implementation process or testing requirements.
6. Receiving timely support, review of testing evidence submissions, technical expertise from MaPS where there are queries and/or to address any issues and defects that may be encountered during the testing and assurance process.
7. The reliance of most of industry on the directly connecting organisations, which would mean that any delays in development or testing schedules will cascade to multiple clients, who are not in control of delivery timelines.
8. The need to implement new monitoring, exception management and operational oversight processes to ensure daily submissions are accurate and resilient.
9. The potential need to resource additional mitigating actions and control processes to ensure tracking and internal reporting of escalations, as well as potentially regulator and client engagement and public announcements if implementation does not meet the deadline.

Question 3

Respondents agreed with the principle of early voluntary and sequential or staggered adoption in advance of a mandatory implementation deadline. Some respondents explicitly agreed the approach to testing and voluntary implementation in advance of the mandatory deadline was deliverable, proportionate and reasonable. These responses highlighted that allowing early adopters to test and implement could help catch issues early, understand whether the solution works as intended, and potentially avoid a sharp cutoff at the point of mandatory compliance.

However, several respondents also highlighted risks and noted again the dependencies on MaPS to deliver the necessary information and a stable test harness (which has now been provided) and test environment, define final testing requirements, support parties through the process, and effectively manage the sequencing (which will be driven by directly connected organisation readiness) and testing windows.

Responses identified practical constraints around sequencing and the need for sufficient MaPS capacity, clear scheduling, and transparent communications. Concerns were expressed that it would not be realistic to implement the changes voluntarily in advance of the deadline if integration testing were to be restricted to only one party at a time, and if such testing was not carefully managed. The concerns centred around the need for information from MaPS on the integration testing process and the timing and sequencing of testing being outside of their control, with the potential for bottlenecks.

PDP response

We have considered the feedback carefully and with our delivery partners. We recognise the ongoing uncertainty around how long the testing and implementation process may take. Indeed, our experience of connecting directly connecting organisations over 2025 and 2026 (where on average connection journeys took longer than originally anticipated and the ranges of durations per stage by organisation were wide), suggests that implementation timelines will be very difficult to predict with any accuracy. We expect the testing process for reporting to be much simpler than the initial connecting testing, but nonetheless recognise the uncertainty surrounding how long it may take and the potential for issues to arise during the process that require technical fixes and cause delays.

Implementation commencement from Summer 2026

We consider that our proposed approach to managing voluntary implementation of parties through a structured testing and assurance process in sequence, as soon as they can, from the summer, remains the right way to proceed. This will ensure key reporting data is flowing through to MaPS and regulators at the earliest opportunity. Since publishing the consultation, we have finalised and made available the test harness to support the first testing stage of system testing, and we are on track to support integration testing by the end of June. It remains our intention therefore that all parties should be able to report daily before the end of November 2026 and we remain fully committed to supporting this.

However, we recognise the proposed timeframe was compressed and left little contingency in case of unforeseen issues arising throughout parties’ implementation that might cause delays. We acknowledge the many concerns raised in the consultation responses that, given uncertainties around the implementation process and how long it may take, the originally proposed deadline may carry a risk of some inadvertent non-compliance. We have listened to the concerns expressed that the proposed deadline would carry the risk that not all of industry may comfortably be able to expect to have completed implementation in time. It is clearly important that industry has a reasonable opportunity to comply.

Revised mandatory implementation deadline

To reduce this risk, we intend to extend the implementation deadline. Subject to approval, we now intend the mandatory implementation deadline for daily reporting via API in accordance with the updated reporting standards to be 1 March 2027.

We have already published the updated reporting standards v2.2 in draft and intend to seek Secretary of State and Department for Communities (Northern Ireland) approval for these updated reporting standards during 2026, and to subsequently publish the approved updated reporting standards as formal standards, with a coming-into-force date of 1 March 2027.

We consider that this extension will appropriately reduce the risk that, due to any issues that may arise through the implementation process, some of industry is not able to have completed implementation ahead of the deadline, and ensure all of industry has ample opportunity to comply.

Manual reporting from Autumn 2026 where implementation is delayed

To ensure MaPS and delivery partners have visibility of key reporting data as early as possible, we intend to require some manual reporting from Autumn 2026 for any directly connected organisations that have not yet been able to implement daily reporting. Manual reporting is the submission of data via file upload, as directly connected organisations have done already to report pension provider and scheme coverage.

This manual reporting will be in addition to the existing requirement to provide coverage data on request. Organisations will report a subset of the existing data required under the current reporting standards, at regular intervals to be confirmed. Where parties have not yet been able to complete implementation of daily reporting, they will need to report these key metrics manually until such time that implementation of daily reporting is complete. We will confirm precise requirements in due course, but we intend to include some of the data on view responses in Part 3 (View responses) of the reporting standards.

Where parties have implemented daily reporting by the Autumn, we have no plans to require any manual reporting in addition.