Vouching scheme requirements and responsibilities

Vouching pension provider or scheme

To connect to the pensions dashboards ecosystem an organisation must have a vouching pension provider or scheme (‘vouching scheme’) that will vouch for them for their connection journey.

This only applies for the initial connection of the organisation. It does not extend to additions of pension providers or schemes through the same connection, once that connection is established.

About the vouching pension provider or scheme (‘vouching scheme’)

The vouching scheme must be a:

• Financial Conduct Authority (FCA) regulated pension provider on whom dashboards duties fall
• The Pensions Regulator (TPR) regulated pension scheme on whom dashboards duties fall

The vouching scheme’s role is to assert that the connecting organisation has a legitimate reason to connect to the pensions dashboards ecosystem (‘the ecosystem’).

The same vouching scheme must be used for preregistration and registration.

A pension provider or scheme that is connecting directly can vouch for themselves. This works in the same way as for third-party organisations connecting directly to the ecosystem.

The vouching scheme will have a role in:

• preregistration
• registration

The vouching scheme will be connected to the live environment on the date agreed between the Pensions Dashboards Programme (PDP) and the connecting organisation during the service acceptance process.

About the connecting organisation

The connecting organisation will connect directly to the ecosystem. This could be:

• an integrated service provider (ISP)
• a third-party administrator
• a pension provider or scheme

A pension provider or scheme may also connect on behalf of other pension providers and schemes.

Vouching scheme interactions

Process flow from a vouching scheme’s perspective

Role of the vouching scheme in preregistration

About preregistration

All organisations that wish to connect directly to the ecosystem must go through the preregistration process before they can access the connection portal. This is to ensure that only legitimate parties can connect.

Data the vouching scheme must provide

The vouching scheme will need to provide the connecting organisation with their:

• regulating body (either the FCA or TPR)
• pension provider or scheme name (as registered with their regulator)
• regulator number (either the Firm Reference Number (FRN) from the FCA or the Pension Scheme Registry (PSR) number from TPR)

Why it is necessary to use real pension provider or scheme information

The use of real pension provider or scheme information is necessary to verify that a connecting organisation represents a pension provider or scheme. This reduces the risk of a bad actor gaining access to the ecosystem.

Data the connecting organisation must provide

The connecting organisation will provide the vouching scheme with:

• the name and email address of:
  • the initial contact at the connecting organisation (if this not one of the primary business contacts)
  • the primary business contacts at the connecting organisation
  • the primary technical contacts at the connecting organisation
• the connecting organisation’s legal name

How data is obtained

From the connecting organisation

The connecting organisation will provide PDP with the vouching scheme’s regulating body, pension provider or scheme name and regulator number. This is submitted as part of the ‘register your interest to connect directly to the ecosystem’ form – part of the preregistration process.

What PDP will do with the data

PDP will use the data provided to confirm the relationship between the vouching scheme and the connecting organisation. They will use the vouching scheme’s regulatory information (regulating body, name and regulator number) to request contact details for a trusted person at the vouching scheme from their relevant regulator, either the FCA or TPR. The trusted person will be the primary dashboard contact for TPR or the person performing the compliance oversight function (SMF-16) for the FCA.

PDP will use these details to email the trusted person at the vouching scheme.

From the vouching scheme

When PDP contacts the trusted person at the vouching scheme, they must confirm:

• the legal name of the organisation they are vouching for
• the name and email address of
  • the initial contact at the connecting organisation (if this not one of the primary business contacts)
  • the primary business contacts at the connecting organisation
  • the primary technical contacts at the connecting organisation

What PDP will do with the data

These details will then be used to verify that they match those provided to PDP by the connecting organisation.

Once a match has been confirmed, PDP will notify the vouching scheme’s regulator.

If the vouching scheme is regulated by TPR, they will send the registration code to the vouching scheme’s primary dashboard contact either:

• once PDP has informed TPR that the connecting organisation has passed due diligence checks or
• 5 months before the scheme’s connect by date in guidance

If the vouching scheme is regulated by FCA, how to access the FCA application from changes from April 2025. The process you follow depends on when you require a registration code:

• Before April 2025: The FCA will issue a registration code application form directly to the person with the compliance oversight function (SMF-16). They will do this once PDP has informed the FCA that the connecting organisation has passed due diligence checks.
• After April 2025: The registration code application form will be accessible on the FCA’s website.

The preregistration process requires real pension provider and scheme information but not real member or customer data.

Where data is stored

The regulating body, regulator number and pension provider or scheme name is stored on the connection portal for as long as the pension provider or scheme is in scope. PDP will delete the personal details of the trusted contact once PDP has carried out the check.

The vouching scheme’s role in registration

About registration

To register on the connection portal, a connecting organisation must have a pension provider or scheme that they will connect on behalf of. The vouching scheme will be the same pension provider or scheme as the one used for preregistration. They will be the first pension provider or scheme for which the connecting organisation would demonstrate compliance with PDP standards.

Data the vouching scheme provides

The vouching scheme will need to provide the connecting organisation with their:

• regulating body (either the FCA or TPR)
• pension provider or scheme name (as registered with their regulator)
• regulator number (either the Firm Reference Number (FRN) from the FCA or the Pension Scheme Registry (PSR) number from TPR)
• the registration code (provided to the pension provider or scheme by their regulator)

Why it is necessary to use real pension provider or scheme information

As part of PDP’s security measures, the connecting organisation uses their vouching scheme’s registration code, regulating body and regulator number to register an account on the connection portal. This reduces the chance of a bad actor accessing the connection portal.

The connecting organisation must then register the pension provider or scheme. This is because the connecting organisation must demonstrate their compliance with the PDP standards on behalf of the pension provider or scheme.

How data is obtained from the connecting organisation

The connecting organisation will provide PDP with all the data required (regulating body, regulator number and registration code) as part of the registration processes on the connection portal.

What PDP will do with the data

The connection portal will use the data provided to validate that the connecting scheme represents the pension provider or scheme and register the pension provider or scheme. This is done automatically by the connection portal, where it will check the details provided against information provided by the regulators.

PDP staff cannot see the registration codes.

The registration process requires real pension provider and scheme information but not real member or customer data.

When the vouching scheme’s legal duties start

Legal duties for the vouching scheme are not activated at the point of agreeing to be a vouching scheme. Legal duties start from the point the scheme or provider is connected under the legislation. That is the date the connecting organisation agrees with PDP on behalf of the vouching scheme that the vouching scheme will be connected to the live environment (this date is agreed during service acceptance).

Where data is stored

The regulating body, regulator number, registration code and pension provider or scheme name is stored on the connection portal for the duration of the pension provider or scheme being in scope. The registration code cannot be read by individuals but is stored in the system.

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Last updated:22/11/2024