UK pensions dashboards: "Act now" says the Regulator

In a recent blog, the Pensions Regulator (TPR) has urged schemes to get on with steps to comply with their pension dashboard duties.  Its particular concern is that schemes may not be sufficiently prepared to connect with the dashboard architecture by their “connect by” date, set out in guidance from the DWP.  

This article considers: 

• TPR’s approach to compliance with “connect by” dates
• Dashboards: what about buy-outs?
• Dashboards: when to report a breach to TPR?

TPR’s approach to compliance with “connect by” dates

As a reminder, there is an absolute connection deadline of 31 October 2026 applicable to all existing schemes (unless the scheme successfully applied to the DWP for an exemption by 8 August this year).  However, to avoid a last minute rush and to allow for sufficient testing, schemes are expected to connect to the dashboard by the “connect by” dates set out in DWP guidance.

A challenge for TPR is that complying with the “connect by” dates in the DWP guidance is not an absolute legal obligation.  Trustees are instead required to “have regard” to the guidance, and we can expect TPR to look for robust evidence of trustees having done so. 

TPR intends to engage with “hundreds” of schemes this autumn, asking them to account for how they are measuring and improving their data in readiness for connection to the dashboard system.  It also plans to send a “Nudge 2” email to all schemes eight months ahead of their “connect by” date.  The first round of such messages has just been sent to large Master Trusts due to connect by April 2025. 

TPR has also recently issued its compliance and enforcement policy for pension dashboards.  The policy recognises that many trustees will be highly dependent on third parties (such as sponsoring employers, administrators, AVC providers and integrated service providers (ISPs)) to comply with their scheme’s dashboard duties.  TPR emphasises that third parties may also be subject to its regulatory powers if they cause a scheme to breach its dashboard obligations.

Where exceptional circumstances mean that a scheme will not be able to comply with its “connect by” date, TPR expects a practical plan for connection to be put in place and a new connection date agreed with the Pensions Dashboards Programme (PDP).

Once connected, a scheme must remain connected at all times, including during any change of administrator.

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Dashboards: what about buy-outs?

A recent “hot topics” article by TPR (which, at the time of writing, appears not to be published on line) contains a reminder that a scheme with 100 or more non-pensioner members is within the scope of the dashboard requirements even if the scheme is going through a buy-out process. 

Once the buy-out is complete, with individual deferred annuity policies issued to all non-pensioner members, the dashboard requirements no longer apply to the scheme which bought out.  Instead, the annuity provider will become responsible for supplying relevant information about members’ benefits to the dashboard system, within specified timescales:

• Administration data within three months of the member’s joining date; and
• Value data (specific information about the amount of the member’s benefits) from the earlier of:
  • The first benefit statement produced for the member; or
  • 12 months from the end of the first full scheme year in which the individual is a member of the scheme.

Trustees of schemes expected to buy-out before the connection deadline may decide not to take steps to comply with the dashboard requirements.  However, TPR is concerned that delays in the buy-out process could result in trustees breaching their dashboard obligations.  Such a breach should be reported to TPR using the breach of law process (see below).  When deciding whether to take regulatory action, TPR will expect to see a robust audit trail of any decisions and will consider the length of the breach and any harm to members.

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Dashboards: when to report a breach to TPR?

TPR has updated its guidance on reporting breaches of law, to add dashboard-related examples.  Using its traffic light approach:

• Failure to connect to the dashboards system by 31 October 2026 will be a “red” breach and should be reported;
• Failure to connect some sections in a multi-section scheme by the DWP “connect by” date, where other sections with a different administrator connect in time, may be an “amber” breach (whether or not to report will require assessment of the trustees’ plans to remedy the situation and whether the 31 October 2026 deadline will be met);
• Failure to align additional voluntary contribution (AVC) illustration dates with main scheme benefits (but nevertheless complying with the DWP “connect by”) date is likely to be a “green” breach, and need not be reported.

As a reminder, certain individuals (including trustees, administrators and sponsoring employers) have a legal obligation to report breaches of the law where they have reasonable cause to believe that:

• A legal duty relevant to scheme administration has been, or is being, breached; and
• The breach is likely to be of material significance to TPR.

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