The Pensions and Lifetime Savings Association (PLSA) has identified 26 key issues that must be resolved to make the initial pensions dashboards a success as part of its recently published pensions industry guide.
The ‘Pensions Dashboards A-Z’ identifies seven key areas that require immediate resolution and decisions. These include testing and managing saver understanding, ISP technical connections with the digital architecture and dashboards, the scheme’s continued GDPR compliance, clarity on the liability regime, the definition of view data to be returned, and clarity on the timeline and regulation of data provision.
The issues identified concern all parties involved in the various layers of the dashboard ecosystem. This includes the Department for Work and Pensions, the money and pension service, the pension dashboards programme, regulators (particularly the FCA and TPR), administrators, technology providers, pension providers, and pension schemes.
According to the guide, extensive testing with a wide range of different savers with varying levels of financial awareness is required to ensure that they understand and are not overwhelmed by the information displayed on dashboards. The testing should also include an examination of what users do after viewing their information. These detailed testing results are critical in defining the display standards that must be used by all dashboards.
Schemes will rely heavily on their current administration and technology providers, as well as newly procured ones, to deliver dashboard compliance. As a result, all administrators and technology providers must be able to see and understand published details about how they must connect with the central digital architecture and dashboards, as well as all necessary technical and security specifications and standards.
Schemes must be confident that by adhering to the dashboard’s compulsion requirements, they will be able to continue to adhere to all existing GDPR requirements. A clear statement of guidance on this subject from the Information Commissioner’s Office would be extremely beneficial.
Schemes require clarification on two separate liability aspects: unfound pensions and pension amounts returned. If a scheme is unable to locate a pension that it should (for example, because personal data does not match perfectly), it will not appear on the user’s preferred dashboard. Separately, the pension amounts displayed on dashboards are almost certainly not the actual amounts payable. Schemes must have certainty as to who will bear legal financial responsibility if users take action, or fail to take action, as a result of I their pensions not being shown and/or ii) the pension amounts they see.
Schemes require certainty on the pension amount data to be returned following the discovery of a pension, both accrued (and, if necessary, projected), across all scheme types (DB, DC, etc.). In addition to a detailed definition of these amounts, schemes must understand how quickly their ISPs must return the required data when a user requests it, as well as how recent the figures their ISPs must return. Response times and the frequency with which schemes and ISPs implement their solutions could have a significant impact on how schemes and ISPs choose to implement their solutions.
Schemes must be aware of the timeframe for compliance as well as the process for onboarding to the dashboards ecosystem. Separately, schemes must understand when the government intends to make pension dashboards public (the Dashboards Availability Point, or “DAP”) to plan additional resources.
Schemes must understand the principles that will be followed by the two respective regulators (TPR and FCA) for dashboard compliance regimes.
PLSA director of policy and advocacy Nigel Peaple says: “Successfully delivering dashboards presents many significant challenges and there is much to be resolved in a short amount of time.
“We hope our guide will help the many hundreds, if not thousands, of people engaged with preparing for pensions dashboards better understand the key issues to be assessed and resolved.
“We know DWP, MAP’s Pensions Dashboards Programme and others are busy working on the issues we highlight here. The sooner the pensions industry has clarity on the seven key issues highlighted here, the sooner progress can be made.”
