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Dashboard due date draws ever closer as draft regulations approved by Parliament

By Eleanor Hart and Emma Holder
November 25, 2022
  • Pensions
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On 17 November, a draft of the Pensions Dashboards Regulations 2022 received parliamentary approval, allowing the staging timetable within which occupational pension schemes must join up to the dashboards platform to be announced. Following approval, the regulations are set to come into force on 12 December 2022.

The first wave of connecting to the dashboard systems is directed at larger pension providers, with smaller schemes not yet within scope and set to be directed to plug in from 2026. For schemes in the scope of regulations, the staging timetable is as follows:

  • master trust schemes that provide defined contribution (DC) benefits only, with 20,000 or more members, by the end of August 2023;
  • DC schemes used for automatic enrolment and DC master trusts with 10,000 or more members must be connected from the end of September 2023;
  • DC schemes used for automatic enrolment and DC master trusts with 5,000 or more members must be connected from the end of October 2023;
  • other schemes, that are not DC including hybrids and CDCs, with 20,000 or more members will be required to connect from the end of November 2023;
  • public service pension schemes must connect at the end of September 2024; and
  • medium-sized schemes, being those with between 100-999 members, will be part of a second wave required to connect from the end of October 2024 to the end of October 2025.

The timings for providers of personal and stakeholder pensions will be separately governed by FCA rules.

To assist employers in the run-up to these deadlines, the Pensions Dashboards Programme (PDP) published updated standards to cover the technical and operational details that will provide a framework for the legislation. In addition, these standards set out data formatting requirements, and the security, service and reporting duties for employers. The PDP has the aim of ensuring users have a safe and consistent experience when using the dashboards – this is especially important given that there still seems to be a degree of apprehension around using online tools to aid retirement planning, with some having concerns over entering pension information online. The rules will come into force once approval is received from the Secretary of State for Work and Pensions.

Given the fast-approaching due date for pension providers and schemes to be connected to the dashboard system, these standards will be vital to assisting them with carrying out their obligations. Further detail setting out design standards will follow once the PDP has consulted on them this winter.

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Eleanor Hart

About Eleanor Hart

Eleanor advises on a broad variety of pension matters, both transactional and general advisory, acting for trustees and corporate sponsors. She has extensive experience advising clients on the pension and employment aspects of acquisitions and disposals (both UK and cross-border). She has been involved in numerous high-profile deals with complex pension aspects as well as innovative pension restructurings, including the first ever pensions deficit for equity swap. Eleanor is a member of the Association of Pension Lawyers and is currently on the Education and Seminars Committee.

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Emma Holder

Emma Holder

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