New pensions dashboards timetable

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The pensions dashboards connection deadline will be pushed back to 31 October 2026 under the Pensions Dashboards (Amendment) Regulations 2023 which were laid before Parliament on 8 June 2023.

The new regulations follow Pensions Minister Laura Trott’s 2 March announcement that the Pensions Dashboard Programme (PDP), the body responsible for delivering the digital architecture which underpins pensions dashboards, was to be reset. That announcement stressed that the framework for dashboards set out in the Pensions Dashboards Regulations 2022 (2022 Dashboard Regulations) remained fit for purpose and that the government remained fully committed to their delivery. 

The Dashboard Regulations originally set out a prescriptive timetable for connection, under which the largest schemes were due to the connect in August 2023, with all other schemes connecting at regular intervals thereafter according to size. However, Ms Trott confirmed that the timetable would be put on hold (and the Dashboard Regulations amended in due course) whist the PDP worked on a more achievable delivery plan. In the interim, the PDP published FAQs addressing the impact of the reset. 

The Pensions Dashboards (Amendment) Regulations 2023 will amend the 2022 Dashboard Regulations so that the series of dates by which schemes must connect to the Money and Pensions Service Dashboard has been deleted. Rather than a staged series of deadlines based on scheme size, the amending regulations set out an overarching connection deadline of 31 October 2026 which applies to all schemes with over 100 members.  

On 8 June 2023 Ms Trott announced that amending regulations are being laid making changes to the existing approach to dashboard delivery which will allow the PDP to work more collaboratively with the pensions industry. The connection timetable will no longer be prescribed in the Dashboard Regulations (once amended) but rather, a staging timeline will be set out in guidance developed in collaboration with the pensions industry. It is hoped that the revised approach will give the PDP the flexibility it needs to ensure the effective completion of an undeniably complex project. 

By putting the staging timeline into guidance rather than into a prescribed timetable, pension schemes can plan ahead knowing that the strict legal obligation for connecting to the dashboard does not fall on them into October 2026. Theoretically they could connect before this date but given the number of other legal changes on the horizon, the reality is that pension scheme trustees will prioritise matters such as GMP equalisation, scheme funding changes and compliance with changes in governance requirements before turning their attention to dashboard connection.  

The government maintains that connection should be mandatory and so the amended Dashboard Regulations will now include an overall connection date of 31 October 2026 to make clear in law that there is a point by which all schemes will need to connect. The nature of that deadline will not be clear until the draft regulations have been made public.  Ms Trott’s statement made clear that 31 October 2026 is not intended to be the Dashboard Available Point. The Dashboard Available Point is the date on which dashboards will be accessible by the public, which Ms Trott confirmed could be before 31 October 2026. 

In the meantime, the Pensions Administration Standards Association (PASA) has issued an update on co-ordinating AVC information for dashboards.  Pension scheme trustees are responsible for ensuring that the AVC element of a member's pension information is made available to dashboards.  However, administration of AVCs is often undertaken by a different administrator to main scheme benefits. PASA's industry good practice guidance outlines potential options for sharing AVC information to the dashboard.  

Disclaimer

This information is for educational purposes only and does not constitute legal advice. It is recommended that specific professional advice is sought before acting on any of the information given. © Shoosmiths LLP 2024.

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