How do you succeed in serving up pensions dashboards to scheme members? It is a bit like creating a complicated recipe. You know how you want your dish to look and taste, but how do you get there?
First, the ingredients have to be listed. Second, the method has to be tried and tested (and it also has to be simple, if you want domestic cooks to follow it, as well as master chefs). Thirdly, the dish has to be cooked to perfection and presented in a way that looks appetising.
How far have we got with cooking up a dashboards recipe?
The list of dashboards ingredients is almost complete. Last week, the Department for Work and Pensions (DWP) published a lengthy response to its consultation on the draft regulations and, with 100 responses, it had a lot to weigh up. The DWP has now agreed a few adjustments to the basics. The summary document highlights the key changes, which include extensions to connection deadlines for large master trust schemes, large money purchase schemes used for automatic enrolment, hybrid schemes and public service pension schemes. The response also confirms changes to the value data that schemes are required to return to pensions dashboards and a modified stance for schemes in a Pension Protection Fund assessment period and for schemes in wind-up.
Before the draft legislation is finalised, the DWP needs to consider responses to its second consultation and, in particular, any comments around how much notice the secretary of state should give before dashboards are made available to the general public (the “Dashboards Available Point”). The consultation suggested that 90 days is appropriate, but this is proving controversial, with many saying that far more notice is needed to allow administrators and pension providers to be equipped to deal with the expected increase in work.
A number of renowned chefs are working together to establish what to do with all of the ingredients. The DWP, The Pensions Regulator (TPR), The Financial Conduct Authority (FCA), the Pensions Dashboards Programme (PDP) and the Money and Pensions Service (MaPS) are collaborating and working in conjunction with other interested parties and volunteers. We hope that many chefs will make light work – the PDP indicated in its last update report that all parties are pulling together and are on track in terms of their individual responsibilities.
TPR issued its initial guidance last month. This includes expectations that trustees will have a compliance plan in place and will be discussing dashboards at trustee board level and with advisers. I commented on this in my previous blog, ASAP x 10. TPR is encouraging trustees, administrators and scheme managers to join its webinar on 28 July at 2.30pm.
Yesterday, PDP threw its dashboard standards into the mix for consultation. This covers the technical and operational detail underpinning the dashboards legislation. The consultation runs for 6 weeks and the PDP is staging a series of webinars to help stakeholders digest the detail.
3. Cooking and Serving
For many reasons, it is vital that dashboards succeed. The ultimate taste-testers are the general public and the pensions information that is presented to them needs to be palatable. The pensions industry has a great deal of expertise to offer in terms of what constitutes successful member communications, and hopefully the PDP’s call for input on design standards (i.e. how the dashboards will look) will receive many constructive responses. We all know that it can be tricky to get the point across that information is purely for “illustrative purposes” without caveating the life out of it.
Continued engagement from the pensions industry is vital – nobody wants the soufflé to sink after all the hard work that has gone into this project.
In terms of next steps, the DWP plans to lay the regulations before parliament this autumn. We can expect a flurry of activity after this, including consultations on TPR’s compliance and enforcement policy, on FCA rules and on MaPS standards.
Do we have a recipe for success? The proof is in the pudding. Personally, I feel optimistic.
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.