In its response, the SPP highlighted the following core areas needing attention in the current regulations and the broader development of the dashboard:
• Clarity over responsibility and liability relating to dashboard activities. Dashboards are an ambitious project, with many new requirements on schemes and providers, and information presented in a completely new way. There remains concern in the industry about what happens if savers take actions or decisions based on information that, despite reasonable care, turns out to be incorrect or misunderstood. Without clarity on this issue, each stakeholder will need to comply with regulations in a way that minimises their own risk, which may not lead to the best overall experience for savers.
• Dashboard standards and regulations, if necessary, must be able to be updated based on experience, and the SPP encourages policymakers and regulators to identify and implement improvements on a regular basis. If the 2022 dashboards regulations and standards, effective for schemes from 2024, are still unchanged in 2034, as was the case 10 years after the introduction of auto-enrolment, then the dashboard project will have failed.
• The Pensions Regulator’s ability to issue penalty notices on a ‘per request’ basis is concerning and needs additional clarity. While the SPP broadly agrees with the proposed enforcement measures, there should be a financial limit on penalty notices where the notices are being issued on a “per request” basis, and the Regulator should provide examples of when a penalty notice would be considered. More broadly, the discretion given to the Regulator in connection with dashboards needs to be used in a proportionate matter, particularly in the early years, and we would welcome guidance from the Regulator as the dashboards program progresses.
• There remains a risk some schemes will not be ready to meet their staging deadlines, but currently there is no flexibility to apply for a deadline extension. While the SPP appreciates the clear, timely ambition of the dashboards project, some flexibility remains in the interest of all stakeholders to ensure the quality and accuracy of the service provided.
Paul McGlone, former President of the Society of Pension Professionals, said: “The Society of Pension Professionals remains very supportive of the pensions dashboard. This consultation covered a number of key areas in a welcome and important step. Inevitably there will be areas where further clarity or progress is needed, and today we have highlighted precisely where in the latest regulations improvements are required. But, notwithstanding those calls for further information, we are encouraged by the progress being made.
“Clarifying issues around liability, design standards and enforcement is now essential. We will continue to work closely with the Pensions Dashboards Programme, the Department for Work and Pensions, and others in the pensions industry, to deliver this clarity and ultimately the successful rollout of the dashboards project.”
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