As we've set out in a previous blog, the current deadline for connecting to pensions dashboard digital architecture is 31 October 2026 for "relevant" occupational schemes with 100 or more members.
The guidance confirms that a scheme is not considered a relevant scheme if:
• its main administration is based outside of Great Britain;
• it is not registrable with The Pensions Regulator (except for public service pension schemes); or
• the pension scheme is a public service pension scheme which is registrable but which relates to persons referred to in regulation 3 of the Civil Service (Other Crown Servants) Pension Scheme Regulations 2016.
DWP guidance: deferring the connection deadline
The DWP has issued new dashboards guidance on applications to defer the connection deadline. It confirms that trustees and scheme managers can apply to defer connection by up to 12 months in specific circumstances, with the deadline for applications being 8 August 2024.
The guidance explains each of the criteria in detail, but in summary, trustees and scheme managers must provide evidence that, before 9 August 2023, they had:
- Embarked on a programme to transfer scheme data to a new administrator; and/ or
- Entered into a contract containing an obligation to retender the administration of the scheme, and the timetable for this is reasonable and conflicts with the connection deadline.
Applications must also provide evidence to show that compliance with the current connection deadline:
- Would be disproportionately burdensome; or
- Would put the personal data of members at risk.
All applications must also outline the steps being taken by trustees and managers to ensure that the scheme can connect at the earliest opportunity.
Next steps
In any event, it is essential that trustees and managers of relevant pension schemes maintain the momentum and continue to prepare themselves for pensions dashboards. For example, schemes should:
- Assess their IT infrastructure capabilities to identify necessary upgrades or adjustments required for seamless integration with the new system;
- Review data accuracy and rectify any discrepancies;
- Establish internal processes and protocols to facilitate the connection with the pensions dashboard system, ensuring a smooth and efficient implementation;
- Communicate clearly with scheme members about the upcoming changes and their implication to build understanding and alleviate concerns; and
- Remain vigilant and stay updated on the latest updates and guidance provided by relevant authorities.
If you would like to discuss anything raised in this blog in more detail, please get in touch with a member of the pensions team or your usual Brodies contact.
