Government is legislating to require all schemes to expose their data to dashboards
The Government has listened to views from across the pensions industry and feels compulsion legislation will be needed to maximise scheme participation in pensions dashboards within a reasonable timeframe.
Consumer research has highlighted that people will expect to see all of their pensions on a dashboard. But international experience shows that, without compulsion, it could take a significant amount of time (over a decade) to deliver complete dashboards with full coverage.
However, the international research also shows that compulsion shouldn’t be introduced too quickly as schemes and providers need time to prepare before exposing data to dashboards. So, the Government is consulting on how quickly, and in what order, schemes and providers should be required to comply. They have also asked whether there’s a case for exempting some very small schemes, such as SSASs or EPPs.
The Government has said it will enact the compulsion legislation as soon as parliamentary time allows, which is very unlikely to be before 2020. At the same time, Government expects the pensions industry to agree a robust delivery model for dashboards, with appropriate governance (see ECOSYSTEM). It wouldn’t be appropriate for Government to compel schemes to expose members’ data to an unsafe environment.
Then, the detailed requirements will be in secondary legislation (i.e. regulations), possibly in 2021, including:
ITM will be watching, and actively contributing to, developments as the dashboard legislation develops. Check back here regularly for a summary of the latest position and expert views on what it means for you.
What’s next? The Government plans to publish the response to its dashboards consultation around Eastertime 2019, which will set out the next steps on introducing the compulsion legislation to Parliament.
The MAPS will convene an industry delivery group to oversee delivery of dashboards
Behind dashboards, a whole "ecosystem" of technology components must work together, including an Identity Service and a Pensions Finder Service, with Integrated Service Providers helping schemes comply.
ITM was a key partner in the 2017 dashboard prototype project, so we know that getting dashboards to work will require collaboration across the whole pensions industry like never before. But it’s really needed to help UK consumers. ITM intends to continue playing a leading role in this.
The Government wants the industry to work together to deliver dashboards (and the technology ecosystem that sits behind them) but it recognises there’s no obvious party to take lead responsibility for doing this.
So it’s proposing that the newly established Money & Pensions Service (MAPS) should take on initial responsibility for convening a Delivery Group (DG) drawn from across the industry. The DG will comprise a Steering Group, an Implementation Executive and various Working Groups.
The DG will govern, oversee and drive the whole pensions dashboards programme. This includes making a whole host of complex decisions:
Importantly, the DG will also need to agree the costs, and secure the funding, for the centrally funded elements of the ecosystem.
ITM will be watching and actively contributing to all these discussions as the MAPS establishes the DG. Check back here regularly for a summary of the latest position and expert views on what it means for you.
What’s next? The MAPS is hoping to appoint a suitable chair of the DG Steering Group in Spring 2019.
Data Regulators will monitor schemes' exposure of data and dashboards' protection of it
With the dashboard compulsion legislation coming into force, detailed new requirements & risks will be introduced into the established UK pensions world. Industry and regulators must work together closely.
ITM's collaboration in the 2017 dashboard prototype project helped surface a range of important and detailed questions about the data that pensions schemes should, and are able to, expose to dashboards. These topics have also been explored in detail by working groups at the:
As the PASA Knowledge Expert partner on data management, ITM remains central to these discussions.
With the Delivery Group (DG) getting underway (see ECOSYSTEM), the industry will settle a range of data standards for the finding and passing of pensions data from schemes to dashboards. Regulators will then need to devise appropriate approaches to monitoring and ensuring that:
Development of the necessary data standards is arguably the most complex part of the whole dashboard initiative. ITM has been at the heart of the detailed discussions to date and will continue working very closely alongside both industry colleagues and regulators as these standards are agreed.
Check back here regularly for a summary of the latest position and expert views on what it means for you.
What’s next? Industry-wide discussions on data standards are continuing and will be given renewed impetus with the publication of the Government’s response to its dashboards consultation around Easter.
Pensions schemes and providers can get ahead by attending to data quality issues now
Data quality analysis or cleanse work already underway, or planned, will stand schemes in good stead prior to dashboard compulsion. There'll also be an opportunity to participate early on a voluntary basis.
ITM is the UK’s market leader in helping schemes with their pensions data management issues. For over 15 years, hundreds of pension schemes, providers and others have benefitted from our data audit and cleanse service, using our powerful web based eDAaRT solution. This focus on pensions data quality will only increase in the run up to pensions dashboards going live.
As the Government brings forward compulsion legislation, the Delivery Group (DG) defines the ecosystem, and industry bodies/regulators define the necessary dashboard data standards, so the detailed requirements on pension schemes and providers will become clearer. All schemes and providers will need to prepare carefully to comply with these requirements from their “compulsion date”.
But schemes don’t need to wait til then. All data quality analysis and cleanse work already underway, or planned, will enable schemes to get ahead and stand them in good stead for when compulsory dashboard participation comes along in the early 2020s.
Schemes are also likely to rely heavily on their in-house or third-party pensions administration (TPA) functions in order to help them comply. Schemes would do well to engage early with their TPA or administration software supplier to understand their plans for supporting their clients with compliance.
The most proactive and forward-looking schemes and providers may not even want to wait for compulsion. It’s likely there’ll be an opportunity for some schemes and providers to join the dashboard ecosystem early, participating on a voluntary basis, prior to compulsion applying. This will be a great chance to help influence the shape of the overall ecosystem for the eventual optimal benefit of UK citizens.
ITM already help many clients with their pensions data management issues. Contact us to find out more, and keep checking back here for the latest dashboard news and expert views on what it means for you.
What’s next? Continue with your existing data management programmes and plans as these will stand you in good stead for dashboard, and engage with your TPA / software supplier to understand their plans.
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