Are you ready to connect to the Pensions Dashboard?

Our pensions experts have been writing about the Pensions Dashboard since the ambitious plans to give people access to all of their pension schemes in one place were announced. The countdown is now on as occupational pension schemes and providers of personal and stakeholder schemes will start connecting to the new pensions dashboard ecosystem in April 2025, with all pension schemes due to be connected by October 2026.

Scheme trustees need to be formulating connection plans with their scheme administrators and ensuring that their data is ready to submit. The new requirements are complex and it is likely that most trustees will look to a third party provider to ensure compliance with the Pension Dashboard Services (PDS). Trustees need to be aware that they will retain responsibility for complying with regulations, making it crucial to ensure that the agreements with any third party providers have compliance built in.

Pension Dashboard Regulations

The statutory duties under Part 3 (regulations 22-28) of the Pensions Dashboards Regulations regarding the provision of pensions information will remain the responsibility of the scheme trustees. These requirements following the connection of a pension scheme are:

  • The requirements relating to the provision of pensions information.
  • Find requests, matching, pension identifiers and view requests.
  • Administrative data.
  • Signpost data.
  • Value data.
  • Contextual information.
  • Operational information and reporting.

These core obligations remain the responsibility of the scheme trustees and will be ongoing. These core obligations however are added to by other ongoing commitments to the Money and Pensions Service.

Money and Pensions Service

The Money and Pensions Service (MaPS) is a non-department government body operating under the auspices of the DWP. The MaPS established the Pensions Dashboards Programme (PDP) in 2019 to develop the dashboards architecture and the necessary governance structures to enable the dashboards to operate. The standards that the MaPS set will also apply to trustees of pension schemes.

Scheme trustees will have duties to cooperate with the MaPS (as far as is reasonably necessary) to assist the MaPS with the exercise of its functions in relation to PDSs. This includes providing information in accordance with service standards and operational standards published from time to time by the MaPS.

Meeting the deadline for connecting the scheme to the MaPS also remains the responsibility of the scheme trustees. Time slippage in IT agreements is known to crop up as an issue so trustees need to be alive to this risk and ensure any service providers are held to the same deadlines.

The scheme trustees will have to comply with relevant standards issued from time to time by the MaPS regarding connection, security standards and technical standards. This is an ongoing requirement that may require updates to systems.

Scheme trustees must also notify the MaPS of any connection issues or systemic issues such as cyber-attacks. This notification must be given "without delay". Other reporting requirements include reporting operational information to the MaPS, Pensions Regulator or FCA in accordance with relevant standards. This "operational information" could include the number of find requests received, the matching process used, the number of view requests received and the time taken to respond to each one, and user contacts including complaints.

It is essential that scheme trustees ensure that any third party provider they engage with complies with these requirements on their behalf, where possible, and that scheme trustees maintain an overview of compliance and an ability to access data quickly to report against.

Advice

Compliance with regulations and the MaPS requirements are not the only potential issues for pension scheme trustees to be aware of when setting up third party provider agreements for pension dashboards. Given the extent of personal data and its availability, cyber security and data protection legislation compliance should also form a fundamental part of any conversation.

Our team of specialist pensions, data, and tech lawyers work together to ensure your agreements are covered from all angles. If you are a pension scheme trustee considering an agreement for third party provision contact us today to let us help you on the path to pension dashboard connection.

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