By Christine Kerr, Principal and Senior Pension Management Consultant at Barnett Waddingham
The Department for Work and Pensions (DWP) has published guidance on a staged approach to connection for Pensions Dashboards, with the revised timeline from April 2025 to October 2026. The Pensions Regulator (TPR) has also updated its guidance to urge the industry to adhere to the revised staged connection timeline.
The Pension Dashboard Programme (PDP) is responsible for designing and implementing the central digital architecture that will make Pensions Dashboards work and setting out various ‘standards’ for providers to adhere to.
The PDP has set out its goals which include connecting people with their pension savings and showing their retirement income, signposting to impartial guidance and empowering pension choices.
Your role as a trustee
While administrators play a key role in the management of this activity, trustees must take action to ensure they are meeting their responsibilities under the Pensions Dashboards Regulations 2022. They need to be satisfied their advisors and stakeholders are engaged in the process. Failure to comply could result in compliance notices and penalties from TPR.
Action points
Establish governance
Trustees should assess if the required governance structure is in place with appropriate stakeholders having oversight. Effective decision making and processes being agreed early will put you in the best position to deliver to the agreed milestones.
A delivery plan should be agreed with providers and progress should be regularly reviewed to ensure the connection date is met. Trustees should check their connection date using TPR’s connect by calculator.
You should:
Decide who will oversee implementation (full board, sub-committee, or subset).
Set up a clear reporting structure.
Use TPR's checklist to monitor progress and make Pensions Dashboards a standing agenda item.
Engage with administrators to agree a project plan – you may have multiple administrators to engage with – defined benefit and defined contribution teams and don't forget the AVC providers!
Agree how decisions made will be recorded and communicated – decide the matching policy and criteria used, plus any changes to this, which need to be kept for a minimum of six years.
Focus on technology
TPR has said compliance and enforcement with the Pensions Dashboards programme will be principles based, data led and pragmatic. It recognises trustees are highly reliant on third parties for delivery, however, the trustees are ultimately responsible for compliance. Therefore, it’s important trustees keep a clear audit trail and detailed decisions log throughout the project.
The Pensions Administration Standards Association (PASA) has also provided useful information to support the implementation of Pensions Dashboards, in particular in relation to the administrative requirements and impacts.
Data and technology are key to the success of an individual’s Pensions Dashboard experience and getting it wrong will result in a lot of additional work, and possible cost. Trustees need to give this careful thought.
Trustees need to have a digital interface to connect their scheme to Pensions Dashboards that meets the Money and Pensions Service (MaPS) standards. This interface could be:
built by the scheme’s third-party administrator or software / IT supplier;
built by the trustees; or
provided by a third-party service provider.
Agree a plan with your administrator(s)/ software / IT suppliers for connecting your scheme to the Pensions Dashboards.
Review and improve 'find data' accuracy
Find data are the data items the Pensions Dashboards ecosystem will send to providers when an individual submits a find request, such as first name; surname; and National Insurance number. It is essential this data is correct on members’ records. The PDP lists all the find data elements that can be used and trustees are responsible for deciding which of the find data items they will match to, so it’s important to understand your data and choose the matching criteria that you are most confident is correct.
Further data considerations include:
Understanding how you will connect and which interface you will use.
Establishing how each provider will connect.
Considering find data accuracy for members and agreeing steps to address any gaps.
Considering aligning any ongoing data cleanse work with any data gap work for efficiency.
Agreeing approach to data matching, including:
what find data you will use;
how you will manage partial matches;
how you will monitor your find data accuracy; and
if you have multiple providers and approaches, understanding the impact on member experience.
You should engage with your administrator(s) / software / IT suppliers to agree an approach.
Consider the member journey
Trustees should engage with their administrator(s) to understand the post-launch member experience, allowing them to shape communications accordingly. Providing information setting out what members can expect will help if there is more than one provider involved in the scheme.
The day-to-day administration team are likely to experience increased member engagement and enquiries. Preparing a member communication plan which supports this may help to ease the transition. The administrator(s) will also experience an increased workload because of partial matches or increased member engagement, or they may need to start producing additional member calculations to meet the required return output. Understand what steps your administrator has in place to ensure there is no impact on day-to-day service delivery.
Address contractual implications
Trustees should proactively engage with administrators to understand any contractual and cost implications as a result of process changes and/or administrators use of a third party to supply data to the Pensions Dashboards.
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