Caught between immediacy and recency: How old can dashboards data be?
Pardon the Interruption
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The government has published its consultation on pensions dashboards regulations, which range from response times to how trustees must prepare before connecting. Schemes will be able to return value data that is up to 12 months old, but is a 12-month-old DC statement still relevant?
The question of whether users will be able to see their pension online straight away after typing in a request came to the fore in the past two weeks, as some industry participants were concerned the government was planning to allow several days for data to be returned, potentially scuppering a smooth user experience.
In its consultation published on Monday, which will run until 13 March, the Department for Work and Pensions seems to have settled on a compromise to allow more schemes to return information quickly. It is now proposing that schemes should return value data – the size of the pension – straight away where a calculation has been made for a benefit statement within the past 12 months. This applies to both defined benefit and defined contribution schemes, despite DC schemes varying significantly in value over the course of a year due to contributions and capital market movements.
If no data was calculated in the past 12 months, DC schemes will have up to three and DB schemes up to 10 working days to return the data to the dashboards, the government has said.
DC schemes: Instantaneous response expected in future
Pensions minister Guy Opperman acknowledged the issue in his foreword, saying the government has been “mindful that initially some schemes may need time to turnaround certain information on the value of pensions for the purposes of dashboards”, but adding: “Nevertheless, it is our intention that this will all become instantaneous in the future.”
The DWP said that “in particular in relation to money purchase schemes, we intend to move towards instantaneous responses for all requests in the future. With this in mind, we want pension schemes to think ambitiously and consider now how they can put mechanisms in place to facilitate the provision of data to dashboards as quickly as possible.”
Mandatory pre-connection steps outlined
As well as being generally required to co-operate with the Money and Pensions Service, trustees and managers will have to complete certain “pre-connection steps”, which the government said will be set out in standards developed by MaPS. They “are likely to include registering with the Governance Register, building (or securing) Find and View APIs and a User Managed Access (UMA) interface, completing software and security conformance testing, obtaining a software certificate from the Governance Register, and completing a test cycle”.
Large master trusts, personal and stakeholder schemes are due to start connecting to the dashboards from April next year; the DWP said that the staging of large schemes should take no more than two years from 2023.
The proposed staging plan is:
large schemes (April 2023 – September 2024)
medium schemes (October 2024 – October 2025)
small and micro schemes (expected to stage from 2026)
Schemes will not need to include pensioners when calculating their size, as the government excludes pensioners from the target groups of the dashboards.
Further consultations are due
The DWP said it aims to lay the regulations before parliament for debate later this year, “when parliamentary time allows”, and pointed out that there will be other dashboard consultations by various government bodies, including the Financial Conduct Authority, which sets rules for contract-based schemes, the Pensions Regulator, which will publish guidance, the Financial Reporting Council, which is set to update its rules on calculating income projections, and the Pensions Dashboards Programme.
Nigel Peaple, director of policy and advocacy at the Pensions and Lifetime Savings Association, said the timeframe to respond to the current consultation is short and that schemes should therefore engage with the topic now.
“It also should be noted that the time from when there will be legal certainty to the point at which the first pensions schemes are expected to connect to the dashboards system looks very short, perhaps only six months. Hopefully, the consultation process will help clarify whether this ambitious timeline is achievable," he added.
Do you agree with the proposal to show pot sizes that are up to 12 months old? Where is the balance between recency and immediacy of data? Richard SmithJon DeanCalum CooperSamantha SeatonChris Curry