On 8 June 2023, Pensions Minister Laura Trott issued a written statement confirming that more time is needed to facilitate successful connection to the dashboard digital architecture and, as part of the reset, the deadline to register with the Money and Pension Service (MaPS) and connect to the dashboards under the Pensions Dashboards Programme (PDP) would be extended to 31 October 2026 for trustees and managers of all affected occupational pension schemes.

The new approach emphasises the importance of collaboration and cooperation with the pensions industry for the rollout of dashboards. They have replaced the staging timeline set out in the Pension Dashboards Regulations 2022 with guidance setting out a revised timeline, which will be developed in collaboration with the pensions industry. It is claimed in the statement "This will give the Pensions Dashboards Programme the flexibility it needs to ensure this complex project is completed effectively".

However, the decision, which comes four years after the service was initially scheduled to be introduced, marks a significant setback to the launch of the pensions dashboard system and has been met with disappointment from consumer groups and providers.

Pensions Dashboards (Amendment) Regulations 2023

The revised approach is set out in Pensions Dashboards (Amendment) Regulations 2023, which was released on the same day as the announcement and came into force as of 9 August 2023. The regulations provide that the connection deadlines set out in the Pensions Dashboards Regulations 2022 and the Financial Conduct Authority’s corresponding pensions dashboard rules discussed in our earlier blog will no longer apply. Instead, these deadlines will be set out in guidance.

In recognition that the requirement to connect should remain mandatory, the regulations include a unified "connection deadline" of 31 October 2026 for all relevant occupational pension schemes with 100 or more relevant members between 1 April 2023 and 31 March 2024 - although the point at which dashboards will be accessible to the public could be earlier.

Further guidance has also been issued by the Pensions Administration Standards Association (PASA) and the Pensions Regulator (TPR).

TPR Guidance

TPR has updated its guidance on pensions dashboards to reflect the revised has approach. The guidance reminds trustees and scheme managers of the significant work involved to comply with their dashboards duties and that they should work with their advisers to assess the impact of the changes and plan how they will meet their dashboards duties.

PASA Guidance

In a press release issued by PASA following the ministerial statement, which mirrors and expands upon TPR's messaging, PASA stressed the necessity for schemes to continue to prepare in line with their service providers’ phased plans. The plans cover the activities required for a scheme to be ready to connect to pensions dashboards. They intend to work closely with the Department for Work and Pensions (DWP), the Money and Pensions Service (MaPS), regulators, trustees, and other involved parties to help define the concept of being "ready to connect" to dashboards and set out what it looks like in terms of a master project plan. In addition, PASA will continue to build on the suite of good practice guidance issued to schemes and service providers so far in areas like data matching and value data preparation.

Key points trustees and scheme managers

Despite the delays, 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 iguidance provided by relevant authorities.

We will of course continue to provide updates as the pensions dashboard situation progresses, including any substantive guidance that comes out. 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.

Contributors

Maureen Burns

Senior Associate

Juliet Bayne

Partner

Sarah Keir

Trainee Solicitor