TPR updates member data guidance to drive dashboards readiness

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The Pensions Regulator has published revised member data guidance and is calling on trustees to treat member data as their most important 'strategic asset', after a large engagement exercise showed that despite overall progress, some schemes need to do more to get dashboards ready. The regulator will expand its engagement in 2026.

TPR’s regulatory initiative found that some schemes still have work to do to get their member data ready for pensions dashboards connection by 31 October 2026 at the latest. While most schemes have made progress on cleansing personal data for dashboards, value data – which is used to calculate benefits – is often overlooked, the regulator said.  

“Good data is the foundation of good governance and a trustee’s most important strategic asset. Trustees are accountable for ensuring member data is correct – no-one else. Maintaining its quality is an ongoing responsibility, because neglect can be costly and have real-world consequences for savers,” said executive director of market oversight, Julian Lyne. 

“With the pensions dashboard deadline less than a year away, the need for reliable data has never been more urgent. The gaps identified in our report risk undermining dashboard readiness and highlight the importance of trustees adopting robust, consistent practices across all aspects of data management. Good data must be complete, accurate, timely, consistent, unique, valid and properly managed,” Lyne added. 

The revised guidance consolidates all of TPR’s data-related guidance. TPR said it sets out clearer expectations and provides best practice examples to help schemes achieve better data management capability. The regulator is now scrutinising the data preparations of the UK’s largest schemes and plans to expand its engagement next year. 

TPR’s recent initiative focussed on measuring data and putting improvement plans in place. It found that improvement plans were “frequently informal or fragmented” and that “trustee engagement ranges from proactive oversight to near-complete reliance on administrators”. 

There was also wide variation in the controls and trustee focus. TPR said administrators often lead data assessments with limited trustee scrutiny.  

The issue is aggravated by past sins, as historical underinvestment has led to what TPR calls a “data debt”, with a quarter of schemes still holding some non-digitised records and fewer than three in five schemes being confident in the accuracy of the common data they hold. 

Do you expect that all schemes will be connected by 31 October?

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