The Pensions Dashboards Programme (PDP) is developing technology which individuals will use to view all their pensions on a personal dashboard when planning their retirement.
Eventually all UK-based pensions must connect to the pensions dashboards, including:
- Defined Benefit pensions (including cash balance schemes)
- Defined Contribution pensions
- State Pension.
It’s an ambitious and complex programme that requires support from the pensions industry, government and regulators. And because it will involve considerable effort, The Pensions Regulator is urging trustees and scheme managers to start preparing now.
To help you with the work required, we keep this list of frequently asked questions updated as the PDP progresses.
Is the Pensions Dashboards Programme going ahead?
Yes. Following the decision to pause and reset the Pensions Dashboards Programme in 2023, revised regulations have been relaunched and need to be complied with.
Will my scheme need to connect to the pensions dashboards?
The Pension Schemes Act 2021 makes it mandatory for the following schemes to connect to pension dashboards:
- Public service pension scheme of any size
- Registered UK occupational pension scheme with 100 or more relevant members.
Small schemes – with fewer than 100 relevant members – are not currently in scope, although they may be included in future legislation. They can apply on a voluntary basis.
What is a relevant member?
A relevant member is an active or deferred member as at the end of the 1 April 2023 – 31 March 2024 scheme year. This will usually be in line with the members listed in the scheme return submitted to The Pensions Regulator by close of play 31 March 2024.
What are the key dates schemes need to plan for?
All schemes with over 100 relevant members will have to connect by 31 October 2026.
A scheme’s total number of relevant members will determine the date by which it will need to connect. For hybrid schemes, the total number of relevant members should include both Defined Benefit (DB) and Defined Contribution (DC) sections.
Pensioners, spouse pensioners and non-UK based payments are not in scope.
The Pensions Regulator will send a letter to each chair of trustees approximately one year before their guideline staging date to notify them of their statutory duties.
Find out your ‘connect by’ date on The Pensions Regulator’s website.
Examples of exceptional circumstances
Example 1: A scheme previously had fewer than 100 relevant members, but these increased to 100 or more by 1 April 2024. Outcome: There are some transitionary arrangements involved, and the scheme has slightly more time to connect.
Example 2: A scheme had 101 relevant members at the scheme year-end date which fell between 1 April 2023 and 31 March 2024, but this number has since gone down to 99 relevant members. Outcome: The scheme is still in scope.
What happened to the timetable for connecting to the pensions dashboards?
The Pensions Dashboards Programme (PDP) team originally published a timetable, prescribing staging and connection dates, according to scheme type and size.
The PDP team has now withdrawn that prescribed timetable. The revised timetable is for guidance only, but schemes are expected to adhere to it. For some schemes – such as those in the middle of a buy-out process – the flexibility will be genuinely valuable, although steps will need to be taken to move the scheme’s connection date.
However, the final connection date of 31 October 2026 remains enforceable.
We strongly encourage schemes to work to the guidance dates. Otherwise, there’s a real risk that too many schemes will leave it until close to 31 October 2026, putting a huge resourcing strain on a number of parties involved in the set-up process – for example the PDP team, pensions administrators, software providers and integrated service providers (ISPs). If a scheme is unable to connect by the guidance date we will need to advise PDP and agree the new date the scheme will connect by.
Consult the staged timetable in full on The Pensions Regulator’s website.
Besides the timetable changes, can we expect other changes to the pensions dashboards?
There are likely to be some changes to all the standards that schemes need to comply with. Several changes are still in draft, and there may be more.
First Actuarial will advise clients on any changes to data requirements as soon as they’re confirmed – on this FAQ page and in separate communications – to minimise wasted effort.
What data does my scheme need to supply?
Trustees must provide two types of data – find data and view data.
Find data
Find data is the member contact information which will be used to ‘match’ members when they search for their pensions on a pensions dashboards.
The recommended industry standard is to match surname, date of birth and National Insurance number. Deviating from the recommended industry standard match data will result in additional work and cost.
View data
View data is the information a scheme will need to return to a dashboard if a successful match is made to a member record.
View data is split into two categories:
a) Administrative data
Administrative data includes:
- Scheme type
- Membership dates
- Relevant information about the employer
- Administration team contact information, in case the dashboards user has any queries
- Links to useful scheme information for the member, such as costs, charges, scheme investments, and trustee or governance reports, where available.
b) Value data
The value data will be used to answer two of a dashboard user’s main questions:
- What (accrued) benefits have I got already (increased to the current year)?
- What (estimated) benefits might I have at retirement?
The values that schemes must supply will depend on whether the scheme is Defined Benefit or Defined Contribution, and whether the member is active or deferred.
What if my scheme is in PPF assessment?
Schemes in PPF assessment before the connection deadline only need to connect if the scheme does not enter the PPF (either by the connection deadline, or within six months of the end of the assessment period if later). This only applies where the whole scheme is in the PPF assessment. If only a section of your scheme is in assessment, your connection duties still apply.
If your scheme, or a section of your scheme, goes into PPF assessment after you’ve connected to the digital architecture, you will need to remain connected. However, you are only required to provide administrative data and messaging confirming that the scheme, or section, is in PPF assessment using the ‘values unavailable’ codes in the data standards.
What if my scheme is in the process of wind-up?
Schemes – or sections of schemes – in the process of wind-up will need to connect to the digital architecture and provide administrative data. However, they do not have to provide member benefits data or value data to members (although they can do so voluntarily).
The Pensions Regulator advises that these schemes should still consider their connection date. But how they should prepare for the pensions dashboards will depend on what stage they’ve reached in the wind-up process.
If they’re at an advanced stage and the connection date starts to look unlikely, they should provide TPR with a plan and indicative wind-up date. They should also keep TPR updated on progress from that point. TPR is less likely to issue fines to schemes that actively work with them.
What if my scheme is changing its administrator?
Schemes that are in the process of transferring administrator – or are planning to do so – may be concerned about the potential impact on preparing for the pensions dashboards.
If you believe that the final connection date of 31 October 2026 is unachievable for your scheme, you should have applied for a deferral before 9 August 2024, demonstrating that:
- You have already embarked on a programme to change administrator or have signed a contract to start the process, and that the timetable is both a) reasonable and b) conflicts with the deadline of 31 October 2026
- Complying with the legislative deadline would be disproportionately burdensome or put members’ personal data at risk.
However, some schemes may start to consider a change of administrator at a later point – in 2025, for example, or 2026 – and will have missed the chance to apply for a deferral. These schemes will need to include any necessary preparations for the pensions dashboards as an integral part of the transfer process.
Potential downtime during the transfer of system to the new administrator is a risk that schemes will need to address in their contingency planning.
If a change of administrator results in a delay in providing value data, The Pensions Regulator will take a pragmatic view – looking at the specific circumstances such as length of delay and the root cause – when applying its compliance and enforcement policy.
How much system uptime must scheme provide?
Schemes will need 99.5% system uptime for their connection to the pensions dashboards, measured on a monthly basis. In the event of downtime, schemes must act swiftly to restore their connection.
Schemes must also give at least five days’ notice of a scheduled service unavailability. And they are required to notify MaPS of any connection state changes.
What do trustees need to do for active Defined Benefit members?
Defined Benefit (DB) schemes must send their active members a statement of the pension they have built up in the scheme. They must also send them a statement of the expected pension at their retirement age, assuming no further salary increases. Both of these figures are usually provided to active members once a year.
What do trustees need to do for deferred Defined Benefit members?
Defined Benefit (DB) schemes must send their deferred members a statement of their deferred pension revalued to the current year. Trustees may also choose to provide an estimate of the deferred pension at the member’s retirement date. Neither of these figures is usually calculated for all deferred members each year.
For most DB schemes, calculating the data for deferred members will be a new requirement. Scheme processes will need to change to calculate revalued deferred pensions for all deferred members once a year.
What do trustees need to do for Defined Contribution members?
Defined Contribution (DC) schemes must send their active and deferred members a statement of the benefits they have built up and an estimate of what they will be at their retirement date. DC schemes already have to provide these figures to members in statutory money purchase illustrations.
How is First Actuarial preparing for the pensions dashboards?
Behind the scenes, First Actuarial has been deeply involved in the Pensions Dashboards Programme (PDP) from the very beginning.
First Actuarial’s Claire Fuller is a member of the data working group of PASA (Pensions Administration Standards Association). As part of this group, Claire has advised the PDP team on:
- Dashboard data issues
- The challenges of getting schemes ready
- The scheme member experience of the pensions dashboards.
First Actuarial has already run webinars on the pensions dashboards, and will continue to do so as more information becomes available.
Claire Fuller also sits on the PDP connection forum, which currently meets on a monthly basis. She also attends bimonthly meetings with the Money and Pensions Service (MaPS) and the PDP team to represent our client base as the changes develop.
Robert Hurst sits on PASA’s Pensions Dashboards Administration Readiness Group. This group is looking at all full impact of the pensions dashboards’ impact on administration practice, including the readiness of matching data, view data and value data.
All of this gives First Actuarial early exposure to pensions dashboard developments. We communicate information to clients in a timely fashion and work with them to plan ahead.
How can First Actuarial help?
If First Actuarial are your administrators, your client manager will contact you around 12–18 months ahead of your connection deadline. We will start to work with schemes in order of size.
We’re ready to help you with pensions dashboards whether or not you are an administration client of First Actuarial. If we don’t provide administration services to you but you would like our assistance in getting dashboard-ready, please contact your usual First Actuarial consultant.
We have documentation and processes in place to support our clients through the dashboards preparation process. And we’ve developed tools for reviewing scheme data to help you become dashboard-ready.
We will provide you with a clear project plan for the work your scheme needs to complete to meet your obligations. And we’ll support you with an ongoing governance document to help trustees to evidence and review any decisions made.
We have appointed Bravura Solutions as our integrated service provider (ISP) and are working with them to ensure your scheme data can be shared to the pensions dashboards.