Progress update report
October 2023
Pensions dashboards will help individuals view their pensions information online, securely and all in one place, thereby supporting better planning for retirement and growing financial wellbeing.
Chris Curry
Principal, Pensions Dashboards Programme
Foreword
This update report is the eighth from the Pensions Dashboards Programme (PDP), looking back at our work since April 2023. Over that period, we’ve made significant progress towards finalising a revised delivery plan that fits with the new connection deadline of 31 October 2026.
This report provides details of our preparations toward industry connection to the dashboards ecosystem. It cannot be stressed enough that it’s vital that pension providers and schemes continue to prepare for dashboards. It’s expected that industry will connect in line with the forthcoming connection guidance, so providers and schemes need to be working through issues such as data readiness now.
As we continue our work towards completing our revised plan for delivering dashboards, it’s also worth revisiting the evidence for the need for dashboards. The report looks at some of the research carried out, including more recent publications, into the lack of engagement with pensions.
Collaboration is an important part of how we deliver dashboards, and this report contains details of how we are engaging with industry in a range of areas. Throughout the year, PDP has produced articles, videos and newsletters explaining dashboards and answering important questions. In the last 6 months, this has included data matching, consumer protection, dashboards available point, the different routes to connection and value data. I’ve also attended a number of events and webinars, speaking to industry and others involved in dashboards, providing updates and taking feedback. This includes the Pensions Age conference, Professional Pensions Live, MoneyHub’s pensions dashboards webinar, PMI’s Pension Aspects Live conference, the Open Banking Expo, and meetings of pension scheme trustees.
I remain truly grateful for the open and co-operative spirit demonstrated by all those involved in making dashboards a reality. Across industry, Government, the regulators and more, there has been a dedication to delivering a service that will help people be more engaged with their pensions, and I want to thank them for everything they continue to do.
Why pensions dashboards are needed
Pensions dashboards goals
The Government is committed to delivering pensions dashboards that will allow individuals to view their pensions information, including the State Pension, together in one online secure place. The goal is to help people clearly understand and be better engaged with their retirement savings. Dashboards will also support the pensions advice and guidance process, providing people easier access to their pensions information when and where they want.
Lack of pensions engagement
It is important that workers across the UK are aware of how much they saved in their pension. Recent analysis commissioned by PDP of Wealth and Assets survey data shows that since 2014, almost 6 million more people in Great Britain have a private pension. Despite automatic enrolment, however, around 12 million people are estimated to be under-saving for later life.
Evidence from many sources make it clear that people are not engaged with their pensions. PDP carried out research in 2022 which found engagement with pension arrangements was low among UK adults aged 18 to 75. The majority (55%) had undertaken no pension engagement activities at all over the previous year. Similarly, ABI research from 2021 found most respondents agreeing that “it can be challenging to access your pension information”.
Building on a wealth of existing evidence around barriers to engagement, the Department for Work and Pensions (DWP) has identified problems of understanding and motivation to proactively seek information on their retirement savings. DWP research from January 2023 on engagement with workplace pensions highlighted people feeling a lack of ownership of their pensions and concern about making decisions that could lead to financial loss.
The benefits of dashboards
Consumers will find it easier to plan for retirement and make more informed decisions with a comprehensive overview of their pensions savings. As part of the ABI’s 2021 research, 56% of people stated that it would be helpful to have all the information on their pension pots in one place. Similarly, PDP has found that estimated retirement income is the most important information that consumers want to see about their pension.
Dashboards will also provide details of pension pots that have been forgotten about, or where a person has lost touch with their pension provider or scheme because they have moved home, for example. The Pensions Policy Institute estimates that 2.8 million pots are not currently matched to their owner, with a total value of £26.6 billion.
At the same time, dashboards present a real benefit to industry. Pension providers and schemes will have opportunities to engage with customers and members who have a better understanding of their retirement savings, supported by pensions dashboards.
Connection
Deadline
In August 2023, amendment regulations published by the Department for Work and Pensions (DWP) came into force, setting a legal deadline of 31 October 2026 for occupational pension schemes in scope to have completed connection to the dashboards ecosystem. FCA are revising their rules to make equivalent requirements for pension providers they regulate. This followed a written ministerial statement in June where it was announced that dates for schemes to connect to the ecosystem would be set out in guidance. It provides flexibility for PDP to deliver a complex programme involving a large number of pension providers and schemes that meets the requirements set out in law.
Providers and schemes must have regard to the guidance on connection when preparing to connect to the dashboards ecosystem, or they may face action from regulators. Providers and schemes are expected to demonstrate they have taken the guidance into account when making decisions, and provide a record of this.
The benefits of connecting in line with the dates in guidance are that it will make it possible for dashboards to be publicly available earlier, it will enable thorough testing to take place sooner and it will ensure users’ experience is positive and safe.
Engagement with industry on the guidance will take place in autumn 2023, with an aim of publishing at a time to provide at least 12 months’ notice ahead of the first connection date in guidance.
Programme plan
Since the April 2023 progress update report, PDP has been focusing on producing a new programme plan as part of its reset activity. This is 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.
Volunteer participants
Work has continued with the programme’s 20-plus volunteer participant organisations on developing the connection journey for the rest of industry. This has been invaluable in ensuring that connection processes are stable and effective when connection begins. As connection progresses, PDP will work with organisations across industry to further refine processes and user experiences.
The volunteer participants are focused on building a direct connection with the dashboards ecosystem to make pensions information available via dashboards. Integrated Service Providers (ISPs) are generally software firms which offer a third-party solution to connect to dashboards on the open market. The pensions administrators in this list are also offering a third-party or in-house connection solution, while the pension providers in this group are developing their own connection solution, in-house. If other firms are intending to build a direct route to connection to provide pensions information, they should get in touch with the programme at supportPDP@maps.org.uk
Collaboration
PDP continues to work collaboratively with DWP, regulators and industry across a range of areas to deliver dashboards. Alongside shaping connection processes and guidance, the programme will engage on the different documents that are necessary for undertaking connection and providing a dashboard.
PDP leads a range of groups and forums to get input from industry on dashboards. These include:
- connection forum: an open forum with volunteer participants and wider industry covering issues relating to connecting to the ecosystem
- dashboards forum: for those interested in developing and hosting a dashboard
- discussion forums: meetings with volunteer participants (initially) dedicated to particular topics and themes such as value data
- connection delivery group: testing and refining products and processes with volunteer participants building a direct connection to the ecosystem
From 2024, PDP will also be launching a user testing and planning group for wider industry, to plan and co-ordinate user activity ahead of dashboards becoming publicly available.
The programme is also an active member of a number of industry, government and regulator-led groups, including:
- ABI dashboard working group: a monthly meeting of ABI members to discuss dashboard-related topics, attended by PDP and partners by invitation
- ABI quarterly meeting: an opportunity for PDP and partners to provide dashboard updates to ABI members
- PASA dashboard working group: working with PASA members on emerging issues relating to dashboards
- software providers group: led by software providers with links to the PASA working group, discussing shared issues and good practice, with PDP and The Pensions Regulator (TPR)
- TPR’s third party administrator (TPA) forum: a monthly meeting for TPAs to discuss various issues including dashboards.
Standards
Legislation empowers PDP to set standards that will provide the rules and controls facilitating ongoing connection to the dashboards ecosystem. Data standards explain how pensions data that will be returned on a dashboard must be formatted by pension providers and schemes. How pension providers and dashboard providers interact with the central digital architecture and each other is set out in the technical standards.
Design standards cover how dashboards will look and how data will be presented on a dashboard. The data that pension providers and dashboard providers will need to report back to regulators, PDP and DWP are described in reporting standards.
A code of connection will also incorporate important standards. Operational standards are what pension providers and schemes, and dashboard providers, will need to follow in order to connect to, and stay connected to, the ecosystem. Minimum service requirements and behaviours to deliver a high-quality user experience are covered in service standards. Finally, security standards set out the requirements that pension providers and dashboard providers will need to meet to deliver a secure service.
In 2022 and 2023, PDP 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 guidance on the staged connection timetable.
Dashboard providers
PDP will be producing further guidance for organisations seeking to provide a dashboard. This will include additional information about the route to become a pensions dashboard service, including the process for connecting to the dashboards ecosystem.
The design standards being produced by PDP will provide minimum requirements for the appearance of dashboards. On top of this, the Financial Conduct Authority (FCA) conducted a consultation on its proposed regulatory framework for dashboard providers. This framework will include rules which will govern the information that users will be presented with on dashboards and other post-view services that a user may be able to access in addition to viewing their pensions savings. The FCA will be providing further information on the outcome of the consultation at a later date. HM Treasury will enable the FCA to publish rules by making an amendment to the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 to include pensions dashboards.
As mentioned above, we set up a regular dashboards forum for those organisations interested in developing and hosting their own dashboard.
User testing
User testing will be carried out to inform the ongoing design and development of the pensions dashboards service. An important aspect will be the user’s experience, ensuring that it is positive, effective and stable. It will include testing and validating the end-to-end user journey, and making sure that dashboard services meet users’ needs, particularly around accessibility.
User research and testing already plays a part in the development and design of the service. It includes user research carried out by the MoneyHelper dashboard team, for example, to inform their initial design and build. However, once connection begins, PDP will then be able to commence the all-important testing of the live service with real data. This will begin with very small volumes initially and gradually increase in the run-up to dashboards being publicly available.
Testing with real data will help provide assurance that dashboards standards are fit for purpose, and will inform future updates. It will also inform the Secretary of State’s decision-making around whether criteria for the dashboards available point (DAP), such as having a positive user experience, sufficient coverage and that the system works effectively, have been met.
PDP will establish a user testing and planning group that will launch in early 2024 to work with industry to develop and coordinate plans for user testing. This will include defining testing requirements and the activities involved, how a range of users will be invited to test the service in a controlled environment, the volumes of users, the notice period ahead of testing, and how insights from testing will be gathered and reported on. This will also support industry with operational planning ahead of DAP.
To ensure transparency for industry and other interested parties, PDP is committed to regularly sharing updates and insights from user testing. Further information will be provided on what this will look like closer to the first connection date in guidance on the staged timetable for connection.
DWP
Following engagement with industry, in June 2023, DWP published The Pensions Dashboards (Amendment) Regulations 2023, which have been approved by Parliament and have now come into force. The Regulations replace the staging profiles previously set out in legislation and set out the deadline for completing connection of 31 October 2026.
The new approach will see connection dates set out in guidance, and DWP has been working with PDP, regulators and industry on laying the groundwork for a connection timetable. In the autumn, we will begin engagement on the proposed staged connection timetable to be set out in in guidance.
FCA
In July, the Financial Conduct Authority (FCA) revised its pension dashboard rules for FCA regulated pension providers to align with the new deadline of 31 October 2026 in the Government’s Pensions Dashboards (Amendment) Regulations 2023. All firms in scope of the FCA rules must have regard to the staging dates that will be set out in the guidance that DWP has been working on with PDP, regulators and industry.
TPR
On 10 October 2023 The Pensions Regulator (TPR) launched a campaign to drive action around data preparation. The campaign is targeted at trustees and administrators, and will run until the end of November. The campaign aims to awaken a sense of duty to prepare for dashboards on behalf of their savers and encourages forward planning and collaborative working between trustees and administrators, highlighting TPR’s checklist as a valuable tool to improve the effectiveness of teams carrying out the tasks.
TPR continues to support trustees and administrators through a comprehensive engagement programme and is also working closely with DWP, PDP and FCA on the development of the staging guidance, including through the provision of modelling.
Key messages for trustees and scheme managers:
- preparing for dashboards will take time – there is a significant amount of work you need to do
- work with those who are supporting you to develop a practical delivery plan – understand what you’ll need to do, when, and where to go for help and support
- use TPR’s checklist to keep track of your progress, and make sure that you maintain records of key decisions made
- get to grips with the data that’s needed for dashboards – accurate data is at the heart of dashboards but it also has significant benefits beyond.
Useful resources
- The Pensions Dashboards (Amendment) Regulations 2023
- FCA’s pensions dashboard rules for pension providers
- TPR’s pensions dashboards guidance
- FRC consultation on proposed changes to the actuarial standard technical memorandum 1 (AS TM1)
- PASA’s updated data matching guidance
- PASA’s value data guidance