DWP has released a written ministerial statement that affects the connection deadline for pensions dashboards.
Additional guidance will be published in due course.

 

Standards webinar: design standards consultation Q&As

This webinar provided an overview of the design standards consultation,  how to respond and FCA’s consultation which is closing in February, hosted by principal Chris Curry and joined by Gary Millar from our Policy team and Francesca Morphakis from FCA.

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

Could you expand on what you mean by consumer protection in terms of dashboards. If it is to avoid confusion/misunderstanding why build in discretion as to how information is displayed and explained?

It’s all about reducing and preventing consumer harms and confusion. Remediation for consumers if things do go wrong, which therefore encourages consumer confidence in dashboards. So, this is about design standards, but it’s also wider eg ensuring the security of the ecosystem, and making sure users have and know about routes to redress.

The discretion to choose how to display shouldn’t be seen in isolation. By requiring the dashboard to present the summary in a detailed manner, then we are building a good foundation of user comprehension and understanding. Consumers can then choose (to the extent permitted by their dashboard) to re-order the presentation (based on this understanding foundation) which they consider meets their needs.

Congratulations all on the 2 consultations. There’s a welcome high bar from FCA for the authorisation of QPDSs, including providing evidence of Consumer Duty-compliant “understandability” testing, ie can the QPDS provider prove they have adequately tested that a range of different user types have actually understood what they have seen. Will the MaPS MoneyHelper dashboard testing be producing similar evidence? Will it be published? If so, when?

In developing the MoneyHelper dashboard, the Money and Pensions Service (MaPS) has (and will) continue to undertake user research and testing to ensure that its proposition meets user needs and provides a good user experience.

User research by virtue of its iterative nature doesn’t lend itself to publication in the way that other research methods do, It will be helpful to share important areas of learning from research and testing on the MoneyHelper dashboard and the central digital architecture. We are looking at how these can be shared effectively.

One of the Government’s 10 Design Principles for online services says: “The best way to build good services is to start small and iterate wildly”. How well does this sit with design standards which can only change annually (or 6-monthly for minor changes)?

The Government Design Principles are primarily aimed at Government’s implementation if its own services. Here we’re building a governing design standards framework for dashboards to implement. They are 2different scenarios.

Changing standards will have an impact on all dashboards and we want to make sure we give them enough notice to update their approach before we update the standards.

We want to get the balance right between stability and certainty for industry planning – a important industry request. Respondents to our earlier consultation on standards were supportive of our proposals for how we would govern the standards and manage change over time, and respondents (which we have put into place).

Our design standards are largely principle based. We think this leaves room for dashboard providers to test the design and iterate an approach that best meet the needs of their users.

How will tranches of a pension benefit be shown on the summary page – will there be a single entry then the detailed information will show the tranches?

In our draft design standards, the summary requires that for ERI values, where the pension is subject to tranches, the dashboard must show the total ERI payable from the beginning of the last tranche. The summary should indicate there is more important information about how the ERI could be paid in the detailed pensions information page.

Tranches could also be shown graphically on the more detailed pensions information page.

Can a dashboard provider advertise their financial services on the dashboard, and specifically the page detailing the member’s various pensions?

The FCA proposes that the only marketing or advertising that will be permitted on a dashboard service is financial promotions for regulated investment advice. Such promotions must comply with requirements for financial promotions in the FCA Handbook . These promotions can appear at any stage of the customer’s dashboard service journey. All other forms of advertising, including product advertising, would be prohibited under the FCA’s proposals.

How does the FCA respond to the challenge that the regulations as proposed could be seen to give an advantage to providers with FCA authorisation over TPR regulated providers who will not be able to offer the same services to members (dashboard provision and data export)?

A TPR regulated provider could, if it chooses, apply to become a pensions dashboard operator. The fact that it is TPR regulated does not preclude it from becoming FCA regulated for dashboard operation only.

Of course, becoming a dashboard operator is not the only way that TPR trustees and administrators (and indeed FCA regulated pension providers) can enable their members to access a pension dashboard. They could, for example, signpost to the MoneyHelperMaPS dashboard, or they could enter into a third-party arrangement with an FCA authorised dashboard operator.

What are your expectations regarding Inclusivity?

We want dashboards to be usable, attractive and used as widely as possible. Our proposals are that dashboards must be at least AA compliant with the industry accessibility standard W3C Web Content Accessibility Guidelines 2.1 (or another equivalent) and must always be designed for use by those with additional or out-of-the-ordinary experiences and needs, and particularly with protected characteristics in mind (for example, we recommend avoiding the use of gendered language). Also, where a dashboard’s users could include customers in vulnerable circumstances with, for example, little pensions or financial services knowledge, the dashboard should be designed with these users in mind.

I note the standards don’t have any mention of what to do on the results screen whilst it waits the 15 to 60s seconds that schemes/providers have to respond?

Our draft design standards do not include specific requirements on dashboards in relation to what to display following the re-direction to the central digital architecture to initiate a find request or whilst waiting to display pensions, only regarding the display of the pensions information when it is retrieved by the dashboard. We think this is a call for the dashboard. But we do set out what the scheme should do when new information has been returned to the dashboard once it has displayed the initial summary of pensions information to the user.

As post-consultation v1 design standards are due in Summer 2023, does this mean the ongoing regular managed change of all standards (including design) will harmonise from April 2024 (for minor changes) and from October 2024 (for major changes), with all these changes being announced in October 2023, ie giving the promised 6 months’ notice for minor changes, and 12 months’ for major?

We consulted on our approach to the governance of standards over the Summer and published an updated version on 21 November. This sets out how we will govern change to the standards once the first version has been approved by the Secretary of State. We expect the first version of approved design standards to be published next summer and our process for change will kick in at that time.

We agree with you that if we were to make changes to design standards if v1 was introduced in Summer 2023, that the earliest date for introducing minor changes would be April 2024 (given the need for 6 months’ notice) and October 2024 (given the need for 12 months’ notice).

Without the ability to export the policy reference might there be limits to use by a Financial Adviser, which is something you are keen to promote?

We want consumers to be well placed to engage in retirement planning, to take the right guidance or advice at the right time and ultimately make informed decisions. The use of dashboards might increase consumer appetite for advice or guidance. However, the information made available on dashboards (administrative details, current value and an estimate of income in retirement) are an insufficient basis alone for an FCA regulated adviser to make a personal recommendation. A full fact-find will still be required, but may be made a little more time efficient when dashboard data is the starting point, even when only part of the pension reference is exported.

The FCA is proposing to allow firms to offer certain types of data export. We are permitting firms to allow customers to export their data to themselves, to the PDS firm or to a member of the same group as the PDS firm with the permission to advise on investments (but only where this is to facilitate investment advice as a post-view service). We propose to require firms to export all view data, except the full pension reference, which can only be partially exported. This is designed to limit the value of exported data to scammers (as it prevents exported data being used to directly initiate a transaction) and we consider this requirement delivers a necessary degree of consumer protection.

The FCA welcomes views on whether this is an appropriate approach, as well as ideas on how else we might achieve this protection.

Please can we have screenshots of the web journey for each of these displays?

It’ll be up to the dashboard to develop its offering with consideration to the FCA Rules, the regulations and our design standards.

Can the PDP share a prototype of the MaPS MoneyHelper dashboard, to help as context for responding to the consultations?

We are considering how we can share the insights from the MaPS user testing as it develops its prototype to ensure that its proposition meets user needs and provides a good user experience.

User research is often iterative and therefore doesn’t lend itself to publication in the way that other research methods do, but it will be helpful to share important areas of learning from research and testing on the MoneyHelper dashboard and the central digital architecture. We are looking at how these can be shared effectively.

Are there plans to explain to members that when they become inactive, the pensions will be removed from the dashboard and that this may not be immediate. Will there be rules on how quickly inactive records should indeed be removed?

The display of the users found pensions only lasts during the user’s dashboard session.