By Louise Davey, Director of Regulatory Policy, Analysis and Advice at TPR
The Minister for Pensions laid amending regulations on 8 June to implement an approach to delivery of pensions dashboards. These regulations include a connection deadline of 31 October 2026, with anticipation that a staging timeline will be set out in guidance.
We acknowledge that there is significant work involved in complying with pensions dashboards. But now that we have a roadmap for delivery, it’s more important than ever that trustees and scheme managers start working collaboratively to progress dashboards quickly and efficiently. A phased and well-planned approach to connection should be maintained so that savers can reap the benefits as soon as possible.
There is a lot of legislative change on the horizon with data being a common, fundamental element across a scheme’s duties. The Department for Work and Pensions and The Pensions Regulator (TPR) expect all trustees and scheme managers to be getting to grips with their member data to avoid competing demands on capacity and other resources. Industry capacity is a big concern, so it’s crucial to plan ahead with third parties and ensure they can comply with their dashboards duties.
The government is committed to making dashboards a success similar to automatic enrolment. Its success has meant more people than ever are saving for retirement. But in addition, a change in working patterns in recent decades means many savers have built up multiple pension pots that can be tough to track.
To put this in context, the Pensions Policy Institute Lost Pension Survey 2022 estimates that there are around 2.8 million lost pots worth over £26 billion. These lost pots, worth an average of £9,470, could make a real difference to savers’ retirements if reunited with their owners.
Pensions dashboards can transform the pensions industry by connecting savers with these pots, allowing people to see all their future pensions entitlements in one online place.
But dashboards will only be as useful to savers as the data they rely on. The success of dashboards depends on good data — having the data isn’t enough, it needs to be correct.
So this is our challenge to trustees, scheme managers and those supporting them in their preparation — to get data accuracy to a point where they’re confident that it can be used in the dashboards environment.
Data challenges
We know administration of pensions schemes is fundamental in delivering good saver outcomes. But historically, this important function has lacked focus and funding. So let’s make no bones about it — getting quality data in the correct format for dashboards won’t always be easy.
The TPR pensions dashboards readiness tracker revealed many schemes’ data quality isn’t where it should be. The results spoke for themselves: only 42% of respondents held all their members’ personal and contact data digitally.
The biggest issues with data accuracy were with deferred members, historical data gaps or members not updating details — and problems with data quality from employers.
The process of preparing for pensions dashboards now shines a light on data quality. Improving this data will have significant benefits beyond dashboards, and with preparation and collaboration will lead to a step change in pension scheme administration.
What must be done?
Trustees and scheme managers must understand the data that’s required to match savers to their pensions, and the data that will be sent for savers to view. You can then audit whether that data is in a dashboards-ready format. All data needs to be accessible, accurate, and available digitally — a scanned document or PDF isn’t enough. Any gaps should be filled as much as possible.
You need to think about the data the system will provide for you on savers, and how you will use this to ‘match’ savers to their pensions. There is no one size fits all approach for matching — the data you use to match will depend on the availability and accuracy of the data you hold for members.
Alongside matching, value data is a fundamental part of the user experience, so this should also be top of schemes’ to-do lists. You will only have a limited time to provide this data — in many cases you will need to return it instantly, and at most you will have three days to calculate a DC value and return it, or 10 days for a DB benefit.
We urge you to work with administrators to assess how much value data you can frontload. Can they revalue in bulk or automate the calculation benefits, to reduce the number of cases you need to calculate within the limited time window?
Don’t fail to prepare
Trustees and scheme managers are responsible for these duties and shouldn’t underestimate the time they’ll take. Time spent cleansing and updating data now will benefit the saver and schemes later.
Inaccuracies and gaps in data will undermine users’ faith in dashboards.
You can’t hurry getting data dashboards-ready. But now is the time for action. Just like prepping for that interview or presentation, trustees, scheme managers and administrators that make time to prepare will reap rewards later.
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