UK Pensions Briefing | Five top tips for pension dashboard readiness

Introduction

The DWP has published final form guidance on the staged approach to connection to pensions dashboards. The guidance sets out a staged timetable for schemes to connect, with the largest schemes being required to connect first. The timeline now runs from April 2025 to October 2026 and is based on the number of relevant scheme members at the scheme year end between April 1, 2023, and March 31, 2024. A detailed staging timetable is set out below.

Top Tip 1: no need to worry about master trusts and GPPs

If you have outsourced your pension arrangements to a third party DC master trust, a stakeholder plan or a group personal pension arrangement, the relevant provider is responsible for connection to the dashboard structure. Any providers operating group personal pension arrangements and stakeholder plans with 5,000 or more members across all such arrangements are to connect to the dashboard structure at the same time as the very largest pure DC master trusts in April 2025, with providers with smaller businesses going in by January 2026.

Subject to the size criteria below, all occupational pension schemes, whether open or closed to future accrual, remain under a duty to connect until every pension is in payment or bought out.

Top Tip 2: no need to worry about small and micro-schemes, yet

Schemes with fewer than 100 relevant members are not in the frame for connection yet. However, the DWP recognises that some trustees or managers of occupational schemes with fewer than 100 relevant members at their reference date may wish to voluntarily connect to the dashboard system. The DWP’s guidance signposts such schemes to the Pensions Dashboard Programme’s own website which will have guidance in due course. 

Small schemes may still fall into the frame if they are open to new members and grow fast enough. If an occupational pension scheme came into existence on or after April 1, 2024, connection should occur by either six months from the end of the first scheme year, or the assigned date that applies to schemes of similar size and type as set out in the guidance, whichever is later.

See Top Tip 5 for how and when to count your members.

Top Tip 3: stick with your plan for readiness

Schemes should by now be well advanced with their connection plans. That plan needs to cover:

• Administration systems – what needs to change in the architecture to hold data in the right form, respond immediately and accurately to “find requests” and deliver benefit illustrations in the correct form?
• Resources – responding to find requests will be a drain on resources – what is your/your administrator’s and advisers’ recruitment plan? Will it survive a run on the market for the few experienced staff around?
• Data – what data is missing or inaccurate and what do you have to do to get it up to the required standard in time?
• Member verification – what data fields will you use to be absolutely sure you are matching an individual to their actual benefits?
• Benefit calculations – what arrangements need to be in place to produce and validate benefit calculations? Can your actuary and scheme administrators deliver and what will they charge to do it?
• What information is missing? If you are in the middle of GMP equalisation or rectification, or you are currently trying to work out what some particularly obscure bits of drafting mean for benefit calculations, how are you going to reconcile that uncertainty with your connection deadline? Talk to us about this – there is a tightrope to negotiate between non-compliance and proving you have done your best in difficult circumstances.

Top Tip 4: work out your staging deadline now

Each scheme required to connect in the first wave has a dedicated staging deadline. Connection has to happen in a short window immediately before that deadline, with the details to be agreed with the Money and Pensions Service (MaPS). The bigger the scheme, the earlier you must complete the process. The big DC schemes are up first but the timetable is very fast.

Getting providers and advisers to deliver changes fast costs money and creates risk. Maximise the time you have to deliver your readiness plan by working out now when your scheme needs to connect and working backwards from there.

You are expected to work out the staging deadline for each of your schemes and get in touch with MaPS at the right time – you cannot rely on the Regulator or MaPS reminding you, although the Regulator does plan to run a series of warm-up letters.

There are two key bits of information you need first: the number of relevant members your scheme had on its reference date, and the category into which your scheme falls. Top Tip 5 explains how to work these out and determine your staging deadline.

Top Tip 5: how to work out your staging deadline

1. Work out your reference date. This is the last day of the scheme year ending between April 1, 2023, and March 31, 2024.
2. Count your relevant members as at your reference date. Relevant members are active and deferred members.

• Do you have all the data splits you need for the calculations below? Now is the time to get them if not.
• If a member has benefits coming into payment at different time e.g. a normal retirement age (NRA) 60 pension and an NRA 65 pension, count them as active/deferred if any element was not in payment on the reference date. Do not count guaranteed minimum pensions separately.
• Hybrid schemes offering DC benefits and defined benefits (DB):
  • Count DB and DC members separately. Do not count AVCs as DC.
  • Count people twice if they have both DB and DC rights.
  • If either the DB total or the DC total is 1,000 or more, check both totals against the Large Schemes table below and go with whichever produces the earliest date. If neither is over 1,000, use the Medium Schemes table below and again take the earliest date.
• If your scheme is formally split up into different benefit or employer sections, aggregate the membership figures. The whole scheme has to connect with the dashboard system for all members at the same time.
• If your scheme had fewer than 100 relevant members on the reference date you may not have to connect to the dashboard structure in this first wave. However, if it is still open to new members, keep an eye on totals. A growing scheme may still have to connect in this first wave of connections. Contact us if that is likely so that we can help you work out your expected staging deadline.
• It is the figure at the reference date that counts, not at your staging deadline. The only exception is if you have no relevant members at all by the time your staging deadline arrives. Bear this in mind if you have bulk transfers or buy-outs in the offing – it might affect your preferred timetable.

3. Check your scheme’s category or categories:

• Only needed if either the DB total or the DC total is 1,000 or more. If not, go straight to step 4 below.
• The options are: non-money purchase (this includes cash balance arrangements), authorised DC master trusts, DC auto-enrolment schemes and other DC schemes. A hybrid scheme may fall into multiple categories but ignore AVCs for this purpose.
• A scheme can fall into the DC auto-enrolment scheme category if it has ever been certified as a qualifying pension scheme on the basis of its DC provision. It does not matter whether you were using strict auto-enrolment or contractual enrolment.
• If on the reference date there was at least one relevant member with DC benefit entitlements referable to the workplace pension enrolment regime, apply the total of all DC relevant members to the DC auto-enrolment column in the table below. Otherwise apply the total to the other DC scheme column.

4. Check your DB and DC totals against the tables below to get your staging deadline. 

You can also check your date using the Pensions Regulator’s updated guidance published on April 12, 2024, which includes a calculator for a scheme’s “connect by” date.

Staging deadlines for large schemes

Staging deadlines for medium schemes

Note: the tables above do not cover public sector schemes, collective defined contribution schemes, stakeholder schemes, personal pensions, group personal pension plans or benefits which have been bought out with annuities. They do cover schemes which have one or more buy-in contracts in place.

What happens if you miss your staging deadline?

The date by which a formal deferral of the staging date could be sought has now passed. If trustees miss their scheme’s staging date, the DWP expects them to co-operate with the Pensions Dashboards Programme to find a new connection date. Missing the ultimate connection deadline of October 31, 2026, may result in enforcement action being taken by the Regulator.