Government sets out conditions for dashboards connection deferral
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Trustees can apply to defer their pensions dashboards staging if they are changing administrator but will still need to provide evidence that complying would be “disproportionately burdensome” or put member data at risk. The government has now explained in what circumstances it would consider such an application.
The dashboards regulations came into force on Monday, setting out requirements to connect to dashboards and specifying how to provide their dashboards service.
In new guidance published on Monday, the Department for Work and Pensions noted that these regulations allow trustees or scheme managers to apply to defer their staging deadline by up to 12 months.
The largest defined contribution schemes will start connecting to dashboards from June next year, with several phases of connection until 2026.
To apply for deferral, trustees must show that they had started the process of changing administrator before the regulations came into force or were contractually obliged to retender the administration of the scheme and the timetable for this conflicts with the staging deadline.
Schemes will need to provide evidence that complying with the staging deadline would be disproportionately burdensome or put the personal data of members at risk.
The DWP has now clarified that it would consider staging to be ‘disproportionately burdensome’ where the cost of compliance “was significantly higher than it otherwise would be if the scheme was not undergoing a change of administrator and the additional cost was not considered to be in the best interests of scheme members”.
However, schemes would have to show that “reasonable alternative options for securing compliance had been considered and determined to be unviable”, otherwise “it is unlikely the Secretary of State will grant a deferral”.
The guidance is much less specific on data risk. The DWP acknowledges that transferring large amounts of personal data between administrators is “a sensitive task that needs to be completed diligently”, but only adds that it remains the responsibility of the applicant to demonstrate why connecting to the dashboards architecture before the deadline would put the personal data of members at risk.
The latest date for making an application will be 11 December 2023.
Do you expect to make a deferral application for one of your schemes?
