Background
Pensions dashboards are secure digital services (apps, websites or similar tools) which are designed to allow individuals to view information about their different pensions in one place online, at a time of their choosing. The Pensions Dashboards Programme (PDP) is a UK wide initiative intended to improve engagement with pensions by making it easier for individuals to track pension entitlements, understand their overall retirement position and support financial planning.
The dashboards framework is underpinned by the Pension Schemes Act 2021, with detailed legal duties set out in the Pensions Dashboards Regulations 2022 (the “Regulations”) for occupational pension schemes, alongside the Money and Pensions Service (MaPS) and PDP standards, and Financial Conduct Authority (FCA) rules for personal and stakeholder pension providers.
For public service pension schemes in particular, pensions dashboards has even broader implications for governance, data quality and operational readiness, complicated by large memberships, legacy records, and complex benefit structures.
The Key Dates: “Connect by” and the Legal Deadline
Under the Department for Work and Pensions (DWP) staged connection guidance (reflected in the Pensions Regulator (TPR) materials), public service pension schemes of all sizes were allocated a “connect by” date of 31 October 2025. Although this is not the strict legal connection deadline, that date does matter as trustees and scheme managers are expected to have regard to the DWP staging guidance when deciding when to connect. Separately, the overarching statutory deadline for in-scope schemes and providers to be connected is 31 October 2026. Even though the staging timetable is guidance (rather than the statutory backstop itself), the regime is designed so that schemes are expected to plan around the published “connect by” dates, document decision‑making, and keep evidence of why any deviation from the earlier staging date was necessary.
Trustee and Scheme Manager Responsibilities
At a high level, scheme managers/trustees of in-scope occupational schemes must:
- Connect to the pensions dashboards ecosystem.
- Be able to receive and process “Find” requests (searching records to identify potential matches).
- Be able to return “View” data (the required pensions information) through dashboards once a match is made.
- Put in place ongoing connection, governance and record‑keeping so that compliance can be evidenced.
Although third parties (administrators, ISPs and software suppliers) will do much of the build and connectivity work, TPR’s guidance emphasises that the legal responsibility for meeting dashboards duties sits with the trustees or scheme manager.
What’s next?
1. “Go live” for members - The dashboards ecosystem has a concept of a public launch point (often referred to as a “Dashboard Available Point” or “DAP”), which determines when dashboards become publicly available. However, scheme duties focus on being connected and ready to respond within the ecosystem by the relevant earlier deadlines. It is not yet clear when exactly public access to dashboards will be made available, however the second phase of consumer testing has recently begun (on 2 March 2026) with MaPS currently recruiting additional testers with the intention of supporting further refinement and improvement of the service before it becomes publicly available.
2. Operational readiness - Operational readiness generally involves establishing clear processes for managing dashboard queries, handling complaints, and communicating effectively with scheme members. It may be the case that a dedicated team or individual must be identified to respond to member enquiries relating to the dashboards, depending on how many queries are received, to ensure that queries are addressed efficiently and accurately. Similarly, it is key to ensure that member communications are appropriate, focusing on providing clear information about the dashboards, their purpose, and how members can engage with them.
3. Data readiness - Effective operation of pension dashboards relies heavily on the accuracy and consistency of member identifiers and data, and if information is wrong there is significant risk that individuals either do not receive information about their entitlements or receive incorrect information, potentially leading to poor decision making. TPR guidance specifically highlights that trustees and scheme managers must ensure the quality of the data is good enough to enable matches to be made, and data should be checked for completeness and accuracy, and be made digitally searchable for dashboard purposes. This is clearly an ongoing process, as member data will continue to change over time. TPR has additional guidance on data quality improvement plans, where trustees or scheme managers have found data issues through review, audit, valuation or other activity.
4. Maintaining connection and controls - Clearly it will be essential for schemes to remain connected within the dashboards ecosystem, and to implement robust controls to safeguard operations. This includes reviewing and maintaining security measures, conducting ongoing monitoring, keeping accurate records, and managing any necessary changes effectively. These measures help to ensure that the scheme remains compliant, provides reliable information to members, and responds appropriately to any developments or incidents.
5. Tracking regulatory and Pensions Dashboard Programme updates - Similarly, it is important that trustees and scheme managers track any regulatory and PDP updates and developments, particularly as standards and onboarding materials evolve over time.
Although the connection deadline for public service pension schemes has already passed, efforts are ongoing to prepare schemes fully for public access to dashboards. This preparation involves more than just establishing and monitoring connectivity, it includes continuously improving data quality, ensuring matching accuracy, and streamlining operational processes to ensure ongoing compliance and so that individuals receive correct responses, subsequently also reducing the potential for complaints.
If you would like to discuss anything raised in this blog in more detail, please get in touch with a member of the pension team or your usual Brodies contact.
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