As we near closer to a new year – and with less than six months until the opening of the first staging window for pension providers and schemes to connect to the dashboards ecosystem – pensions dashboards preparations are well and truly underway. Back in September we published a blog in which we discussed the government's response to its consultation on draft regulations containing various requirements for pension providers and schemes. Fast forward a few months and the Pensions Dashboards Regulations 2022 - laid before Parliament on 17 October 2022 - have now been formally approved and came into force on 12 December 2022 ("Regulations"). The Regulations provide for a mandatory staging timetable for pension schemes and their providers, scheduled to commence in early 2023 with all in-scope schemes required to connect to the dashboards infrastructure by 31 October 2025.
What are the duties under the Regulations?
The Regulations set out the requirements for pension providers and schemes to connect to dashboards and indicate what organisations must do to provide a qualified dashboard service by their staging deadline. In particular, trustees of in scope schemes will be required to:
• register with the Money and Pension Service (MaPS) and connect to the dashboards;
• be in a position to receive personal information on members, and search and match members to their pensions (‘find requests’);
• be in a position to provide members with information about their pension through the dashboard of their choosing upon request (‘view requests’);
• co-operate with MaPS when preparing to connect, maintain records and report certain information to The Pensions Regulator and MaPS, including any change in connection arrangements or any connection issues caused by system maintenance or cyber-attacks.
Find requests
Once a find request is received, schemes will be required to cross check the information contained in the find request against member records held in the scheme, with the aim of finding a match. Trustees will also be required to put in place a matching policy which includes the criteria their scheme will use to identify both positive and possible matches. The chosen criteria will depend on the availability and accuracy of the data held in the scheme as determined by the Trustees. On this basis, trustees who have not already done so should audit their scheme data with the help of their advisers and put in place a plan to improve and/or digitise the data if necessary.
View requests
Upon receipt of a view request, schemes will be required to provide:
• administrative data – details of the scheme, administrator and relevant employment;
• signpost data – a link to a website containing information on member-borne costs and charges, the scheme's statement of investment principles and implementation statement;
• value data – details of accrued and projected pension values. The value data required will depend on member status and benefit type.
Looking to the future
With the legal and regulatory framework that will underpin pensions dashboards now confirmed and the first staging dates fast approaching, trustees should ensure that they have an implementation plan in place in order to ensure that their scheme is in a position to meet the requirements under the Regulations. The key action points for trustees are as follows:
• consider what steps they should take to improve the accuracy and quality of their dashboard data;
• decide on their preferred matching criteria and produce a matching policy;
• carry out a Data Protection Impact Assessment in relation to the matching process which should identify the associated data protection risks and the steps being taken to mitigate these;
• consider how they will calculate the pension value data that will need to be provided to members;
• review and, if necessary, update their contract with their scheme administrator and any other relevant service providers.
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.
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