United Kingdom: Pensions dashboards timetable published

04 Apr 2024    2 minute read
Dashboards

In brief

Following the Government's extension of the pensions dashboard connection timetable, it has now published statutory guidance setting out the date by which trustees should connect their schemes to the pensions dashboard system. Whilst the only statutory deadline by which schemes should connect is now 31 October 2026, the guidance sets out a "connect by" timetable, and the DWP is encouraging trustees to follow the dates relevant to their scheme. The largest master trusts are expected to connect by 30 April 2025 and the latest date specified is 30 September 2026. All pension schemes must have connected by the statutory deadline of 31 October 2026.

As we have previously indicated, trustees should work with their administrators to ensure that their schemes are ready to connect by the recommended deadline and that their scheme data is fit for this purpose.  More industry guidance will follow this year to assist trustees.

Contents

  1. Further detail
  2. What next?
  3. Key takeaways

Further detail

Following extensions to the original pensions dashboards timetable to provide extra time to develop the required dashboards technology, the Government has now published recommended "connect by" dates for pension schemes. These are set out in statutory guidance issued by the Department for Work and Pensions ("Guidance"). The earliest "connect by" date is 30 April 2025 for the largest master trusts, and the latest date specified for smaller schemes is 30 September 2026.  The statutory deadline for connection is 31 October 2026.  An online tool has been created by the Pensions Regulator to help trustees determine their "connect by" date.

Whilst the timetable itself is not mandatory, trustees must, by law, have regard to the dates in the Guidance and so trustees are being strongly encouraged to comply with the timetable unless there are exceptional circumstances that would prevent them from doing so.  In addition, the Government is encouraging trustees to follow the dates in the Guidance to contribute to the successful delivery of pensions dashboards.

What next?

Further guidance for the industry is expected over the coming months:

  • Guidance issued by the Pensions Dashboards Programme (PDP) will provide further detail on the process of connecting to the pensions dashboards ecosystem.The  PDP will also produce connection and testing materials to support schemes in their connection processes.
  • The Pensions Regulator has issued guidance to support schemes with connecting and supplying data to the pensions dashboards ecosystem.  The Pensions Regulator is also undertaking a "nudge" programme to remind trustees of their duties in this area as they approach their connection date.
  • The Pensions Regulator will also be publishing their revised compliance and enforcement policy by the Summer and we understand that they will also be producing a pensions dashboards "toolkit" to assist. trustees.

Key takeaways

Now that the relevant connection timing has been confirmed, trustees should prioritise working with their administrators to ensure they are ready to comply with their pensions dashboard duties.  If they haven't already, trustees should also review their administration contracts to confirm that they adequately address the scope of work that administrators and any contracted third parties are undertaking to meet the trustees' duties in this area.

The Guidance can be found here.

Please speak to your usual contact at Baker McKenzie if you would like to discuss this area further.

Contact Information
Tom McNaughton
Of Counsel
London
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tom.mcnaughton@bakermckenzie.com
Emma Holder
Associate
London
emma.holder@bakermckenzie.com
Victoria Thompson-Hill
Knowledge Lawyer
London
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victoria.thompson-hill@bakermckenzie.com

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