The Pensions Regulator (TPR) is not pulling any punches in its latest messaging around pensions dashboards.
The Deadline campaign, launched on 22 June 2022, follows research conducted by TPR revealing that insufficient progress has been made by schemes in preparing for pensions dashboards and moving towards the level of digitalisation of member records that will be required. The research shows that 63% of schemes have not yet discussed dashboards at trustee board level. 63% seems like a lot. Hopefully, none of the 63% are those with staging dates in 2023 – otherwise time is in short supply if compliance is going to be a smooth process.
TPR’s initial guidance, based on draft regulations issued by the DWP, summarises what it expects trustees to do. If you have a basic familiarity with dashboards, the guidance is a fairly quick read. Importantly, it sets out a checklist/timetable for compliance. If there is already a plan in place for your scheme, it would be a good idea to check this against TPR’s action plan, to see if there are any gaps or mismatches in terms of timeframes. If your scheme does not yet have a plan, now would be a good time to reassess this.
The checklist contains 10 items marked as “ASAP”, including that trustees should read the guidance and make sure that dashboards are discussed regularly at trustee meetings. Other actions are based on the scheme’s connection date, with the expectation that some decisions will be made 12-18 months before connection – meaning that schemes due to connect by the end of 2024 should already have a plan. However, TPR strongly advises early preparation for all schemes, irrespective of connection dates.
David Fairs (TPR’s Director of Regulatory Policy, Analysis and Advice) warned: “Schemes should be taking action now – their connection deadline is coming…Trustees will have legal duties they must be ready for. We will take a dim view of trustees who carelessly fail to prioritise their dashboard responsibilities.”
If you feel that your scheme may be lagging behind, then here is your call to action. This may not be welcome news with summer holidays looming, and other major projects such as single code of practice compliance and GMP equalisation to deal with, but TPR’s messaging seems to represent a press on the accelerator. The pace of change will continue to speed up this summer with the DWP’s response to consultation expected in the coming weeks, and the Pension Dashboards Programme’s consultation on dashboards standards. Our recent video and handout may also be useful, for those who need a kick-start.
The opinions expressed are those of the author and do not necessarily reflect the views of the Firm, its clients, or any of its or their respective affiliates. This article is for general information purposes and is not intended to be and should not be taken as legal advice.