On October 17, 2022, the DWP published its response to the consultation opened in June 2022 that sought views on:

Having reviewed the responses to the consultation, the DWP acknowledged that its original proposed 90-day pensions dashboards lead time was challenging for schemes and administrators. Regular updates will be provided and a formal notice will now be issued at least six months before the project goes live, in order to allow schemes longer for their final preparations. Formal notice will not be given until the Secretary of State is satisfied that the dashboard system is ready to support widespread public use. The thinking is that the extra warning time will give schemes the opportunity to put in place the necessary capacity to cope with any early surge in members’ engagement. There is no change to the substantive provisions around exclusions from connection, and a scheme that is winding-up on its staging date will still be required to stage. 

 

The consultation response also confirmed that the proposals concerning disclosure of information between the Regulator and the MaPS will proceed largely as planned, together with an amendment enabling the Regulator to share restricted information in respect of the MaPS’ dashboard functions. Such information sharing will not override safeguards in the Data Protection Act 2018 or the UK GDPR.

 

The provisions under the Pension Schemes Act 2021 putting in place the legislative framework for establishing a qualifying dashboards service were brought into force on October 14, 2022. The draft Pensions Dashboards Regulations 2022 were laid before Parliament on October 17, 2022. In addition to the changes outlined above, the regulations exempt schemes already in a PPF assessment period before their staging deadline from the connection requirements. The regulations will need to be approved by both Houses of Parliament before they can come into force.

 

The DWP has also issued draft guidance for trustees on matters to consider if they wish to apply for a deferral of their scheme’s staging deadline. There is limited flexibility for schemes to make a one-off application to defer their staging date by up to 12 months. This applies, for instance, where the scheme’s data was already being transferred to a new administrator, or there was a contractual obligation in place to retender the scheme’s administration, at the time the regulations came into force. If these circumstances apply, evidence will need to be provided that complying with the scheme’s original staging deadline would be disproportionately burdensome or that it would put members’ personal data at risk. However, it is important to note that the application for deferral needs to be made within 12 months of the regulations coming into force. The deadline is not linked to the scheme’s staging date. The guidance will be updated when the final regulations come into force.