Pensions dashboards are now firmly in the implementation phase. As explained in our previous blog, pensions dashboards are online portals, capable of showing information about all of a person’s lifetime savings. This blog focuses on dashboard obligations for occupational pension schemes. Personal pension providers are subject to separate requirements and guidance under the FCA regime. The Pensions Regulator (TPR) has been clear that trustees must not delay preparation for connection and that message has continued into 2026 as connection activity accelerates across the market.
TPR’s latest guidance issued in November 2025[1] makes clear that schemes remain in scope unless a buy-out is legally complete by 31 October 2026 and that “waiting for buy-out” is not a valid reason to defer preparation. Trustees who fail to connect on time risk regulatory enforcement action. TPR also emphasised that defined benefit schemes cannot assume they are exempt, even if they are progressing towards buy-out or wind-up. The Pensions Dashboards Programme’s (PDP) December 2025 progress update[2] confirmed that scheme connection is now well underway and emphasised the need for early data preparation and testing.
The bigger picture
Dashboards are not just another compliance exercise – they are part of the wider global shift towards digital transformation. Other industries have already made this progress from banking apps to online healthcare and pensions dashboards are the sector’s contribution to that journey.
When handled well, dashboards have the potential to improve scheme administration, strengthen member confidence and support major projects such as de-risking, bulk transfers and consolidation. They should be approached as an opportunity to modernise, not simply as a regulatory requirement. The PDP aims to enhance transparency and member engagement by allowing savers to view all their pensions (workplace, personal and state) through a single online platform.
Dashboard obligations
For members, dashboards will make it easier to track entitlements and plan for retirement. For trustees and employers, however, dashboards represent a significant delivery project, touching on data governance, systems integration and record accuracy.
Deadlines are now well underway:
- Master trust schemes – staged deadlines throughout 2025, latest cohorts deadline passed on 30 June 2025.
- Larger schemes (primarily those with more than 1,000 members) – staged deadlines throughout 2025, latest cohorts deadline passed 30 November 2025.
- Medium and smaller-sized schemes (primarily those with up to 1,000 members) – staged deadlines begin on 31 January 2026, with a final backstop of 31 October 2026.
While October 2026 may appear distant, both TPR and the PDP continue to stress that data quality is the single biggest barrier to successful connection. For many schemes, the volume of work involved means the effective deadline is much earlier.
To support schemes, the Pensions Administration Standards Association has published updated Data Quality Guidance and a Data Improvement Plan template. These align closely with TPR’s focus on six data dimensions (accuracy, completeness, consistency, timeliness, uniqueness and validity) and provide trustees with a structured framework for identifying and addressing gaps.
Trustees who leave data work too late risk delay, regulatory scrutiny and disruption to wider projects such as buy-outs, transfers or consolidation.
Practical implications for clients
Trustees
For trustees, high-quality, reliable data underpins dashboards compliance. Incomplete or inconsistent member records remain the most common cause of connection delays and leaving this work too late increases the risk of regulatory action. Trustees should engage early with administrators and IT providers to confirm system readiness, while maintaining clear governance records to evidence planning, responsibility and oversight.
Employers and sponsors
For employers and sponsors, dashboards should be factored into broader strategic planning. Connection duties remain until a buy-out or wind-up is legally completed, so overlooking dashboards obligations can affect transaction timing and costs. Dashboard preparation should also align with wider data initiatives – high-quality data supports compliance, improves transaction pricing and reduces the risk of disputes. Employers should also anticipate increased member engagement once dashboards make entitlements more visible.
HR and finance teams
Dashboards are likely to change how employees interact with their pensions. Easier access to information is expected to increase member queries, particularly around historic service and benefit levels. This will place additional pressure on HR and finance teams, making forward planning essential. Budgets may also need to reflect continued investment in data and system readiness over the next
12-18 months.
What should I do next?
Trustees and employers who act early will be better placed to avoid disruption and benefit from the use of dashboards. Some practical steps to take now include:
- making dashboards a standing item on board agendas;
- prioritising data cleansing and quality assurance;
- confirming system compatibility with administrators and suppliers;
- reviewing governance documentation to evidence planning and accountability; and
- allocating budget and internal resource for member engagement post-connection.
The PDP is now in active delivery. While the final statutory deadline is October 2026, regulatory expectations and operational pressures mean that the groundwork cannot be left until the last minute. As TPR has warned, “there is still a lot to do”. Acting now will reduce cost, minimise risk and support a smoother experience for members.
If you would like to discuss dashboards compliance or how it aligns with your wider pensions strategy, please get in touch.
[1] The Pensions Regulator (2025) Trustees urged to get dashboard-ready by treating member data as a strategic asset [Press release, 18 November]. Available at: https://www.thepensionsregulator.gov.uk/media-hub/press-releases/2025-press-releases/trustees-urged-to-get-dashboard-ready
[2] Pensions Dashboards Programme (2025) December 2025 Progress update report. Available at: https://www.pensionsdashboardsprogramme.org.uk/progress-update-report
Lucy Cleary is a Trainee in the Dentons Pension team, based in the London office – for any further queries in relation to the above, please contact lucy.cleary@dentons.com
