The Pensions and Lifetime Savings Association (PLSA) has called for more detail about how The Pension Regulator (TPR) intends to investigate ‘more nuanced and complex’ breaches of dashboard compliance.
TPR held a consultation on a set of measures for enforcement in the event of a legislation breach and outlined expectations for trustees and scheme managers to achieve compliance.
In a published submission to TPR titled ‘Dashboards Compliance and Enforcement Policy Consultation’, PLSA has highlighted three areas of worry such as how the regulator intends to enforce compliance.
It also highlights issues relating to data matching at launch. Throughout the testing and launch phases, TPR must adopt a practical approach and, ideally, define acceptable matching rates.
Finally, given that certain data inaccuracies will inevitably remain outside of their control, schemes, and particularly MTs, would benefit from understanding where the regulator plans to set the bar in terms of data quality.
This consultation is a result of the Pensions Dashboards Regulations 2022 adding new responsibilities to some trustees and scheme managers to make dashboards work and then giving TPR new authority to oversee the responsibilities.
Additionally, the legislation gave TPR new legal authority to pursue third parties when they believe that they are to blame for the scheme’s violation of the Dashboards Rules.
PLSA director of policy and advocacy Nigel Peaple says: “We welcome the overall pragmatic approach taken in the draft policy. It is clear that TPR wishes for the compliance and enforcement measures to be workable in the face of the well-understood challenges that will be encountered during the staging process.
“There remain some areas where further explanation of intent is required. These areas relate to how the regulations will be enforced in complex circumstances with potential issues that could arise as schemes begin to connect. Ideally, TPR would also provide clarity over acceptable matching rates during the testing and launch, as well as where the bar will be set with regard to data quality as certain data inaccuracies will be beyond schemes’ control.
“The pragmatic approach taken by the regulator is essential to securing an outcome that delivers a strong framework of compliance and enforcement, whilst also ensuring schemes can practically deliver on what is required of them.”