The Association of British Insurers has said industry should not be held liable for delays beyond their control in meeting the pensions dashboards deadlines because these depend heavily on technical providers not in scope for proposed regulations, and has stressed the need for a use case to make people return to dashboards. 

 

On 13 March, the government’s consultation on dashboards regulations closed, just six weeks after being launched, with the intention of laying regulations before parliament later this year. 

 

At the time, the Pensions and Lifetime Savings Association’s director of policy, Nigel Peaple, said that it was not just the consultation period that was short: “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 said. 

 

 

The Department for Work and Pensions’ proposed staging plan is that large schemes, based on their number of active and deferred members, start connecting to the dashboards from April next year, with medium sized schemes following in 2024: 

 

 

While the government may have chosen a deliberately ambitious timeline to spur industry into action, the industry is nonetheless concerned. Schemes and administrators are still in the middle of big projects like guaranteed minimum pensions conversion or McCloud.  

 

Law firm Sackers suggested piling dashboards compliance on top of this could be the straw that breaks the camel’s back. Final regulations are not due until later in the year and there is “no sight yet of the draft accompanying standards and guidance”, said Emily Forrest, a partner in the firm. The proposed timeframe for compliance therefore "seems somewhat ambitious”, she said. 

 

“With the industry still dealing with the aftermath of the pandemic, and any number of developments and projects which have been delayed as a result, there is little time to get ready. We therefore think it would be helpful if TPR could confirm that it won’t take any enforcement action until dashboards go live,” Forrest said, as this would give the industry time to make sure the data is ready. 

 

The ABI, which was involved in creating a prototype dashboard, was less concerned. “The timeline in the consultation broadly looks achievable for our members,” said Rob Yuille, head of long-term savings policy. 

 

“The concern is more around dependency,” he said, from firms that are outside the legislation. “Industry is depending on the technical architecture to be ready [and relies] on outsourcers and the expectation of the [integration service provider] market who make data available to the dashboards.” An ISP is a layer between pension schemes and dashboards to integrate pension systems into the dashboard without having to connect the two systems directly. 

 

    
These factors, that can impact the timeline, are “outside industry’s control”, said Yuille, arguing that it is concerning that the pensions industry is held accountable for a timeline it cannot entirely control. 

 

The ABI is however pleased with the DWP’s proposals to enable data to be exported from the dashboards. “We think that’s critical. They didn’t have to talk about it in the regulations, it’s not in the legislation – but it is an important issue that needed surfacing,” he said. 

 

This is because the dashboards will not allow financial transactions – exporting data will therefore be the only way that users can take any action as a result of accessing the dashboards, by exporting data to a pension modeller, for example. “We know from our research that people do expect that,” Yuille noted. In its consultation response, the ABI said it would like the DWP to give more consideration to allowing transactions and calculators on the dashboards. 

 

 

User research conducted for the ABI showed that 53% of consumers said they would use the pensions dashboards, but also that once they have looked at it, will forget about it again. 

 

Evey Tang, an ABI senior policy adviser, said that many users will not take action on the back of the dashboards, making it important to create a use case. 

 

“Even if we have a dashboard that presents data in a relatively simple format it’s still important to make sure users know what to do with it," so that the dashboards can fulfill one of their aims – supporting retirement planning, she said. 

   

   

Tang said encouraging people to come back to the dashboards would require a smooth user journey, including complete data and prompts. Based on the user research, “there is very little tolerance of incomplete data already,” she observed. 

 

The project should focus much more on user needs, she said, and if possible more user testing should be done.