Government is legislating to require all schemes to expose their data to dashboards
As soon as Parliamentary time allows, the Government is going to make new primary legislation to compel all pension schemes and providers to expose their members' or customers' data to pensions dashboards.
The new compulsion duties will apply to different schemes in stages, with the largest schemes expected to be in the earlier stages in order to maximise early participation. Large defined contribution (DC) schemes are expected to be among the first schemes. Early voluntary participation is also an option. The Government is also working towards including State Pension data in dashboards at the earliest possible opportunity.
The Government hopes to introduce a Pensions Bill later in 2019 including the dashboard compulsion provisions. This will become Pensions Act 2020. Secondary legislation (i.e. regulations), probably coming in 2021, will then define exactly what schemes must do, the date from which each scheme and provider will be required to comply, and whether or not any small schemes will be exempt from the compulsion requirements.
At ITM, we believe the compulsion "window" is therefore likely to start in 2022. Government expects schemes to be providing data to dashboards within four years of the first voluntary dashboard being launched in 2020. So we currently anticipate a circa two-year compulsion window from 2022 to 2024.
What’s next? The Government plans to introduce a Pensions Bill later in 2019 including compulsion provisions. ITM is actively contributing to the emerging thinking. Check back here regularly for a summary of the latest position and expert views on what it means for you.
MAPS is convening a delivery group of experts to deliver the dashboards ecosystem
Behind dashboards, a whole "ecosystem" of different technology components must work together within a sophisticated digital architecture. The Money & Pensions Service (MAPS) is recruiting experts to form a delivery group to define, develop or procure all these components.
ITM was a key partner in the 2017 dashboard prototype project, so we know that getting dashboards to work will require technical collaboration across the whole pensions industry. To lead this industry-wide collaboration, MAPS is recruiting a wide range of experts to form a dashboards delivery group. Chris Curry has now been appointed Principal (or Chair) and the Implementation Director of this delivery group is currently being recruited. The delivery group's many tasks include:
ITM is actively contributing to these discussions as MAPS establishes the delivery group.
What’s next? MAPS will announce the name of the delivery group Implementation Director. The aim is for the delivery group to be operational by the end of the summer of 2019. Check back here regularly for the latest updates and expert views on what it means for you.
Regulators will monitor schemes' exposure of data and dashboards' protection of it
Sitting beneath the dashboard compulsion legislation, there will be a set of detailed data standards which must be adopted so that pensions can be securely found and consistently shown on dashboards. Regulators will closely monitor adherance to these standards.
ITM's collaboration in the 2017 dashboard prototype project surfaced a range of important questions about the data that should be shown on dashboards. Starting in 2019, the MAPS delivery group (see ECOSYSTEM above) will commission user testing in a controlled environment to understand consumers' needs and agree what data should be shown.
Industry must then work closely with the delivery group and regulators to agree the necessary data standards so that the required data can be securely found and consistently shown on dashboards. It is likely that the inital data requirements will be small but grow over time. Similarly, dashboard functionality will start with a simple "find and show" service, but is expected to develop over time, with changes to the data standards as appropriate.
ITM has been at the heart of the detailed data discussions so far and will continue to work very closely alongside both industry colleagues and regulators as the data standards are agreed.
What’s next? Industry-wide discussions on dashboard data standards are continuing and will have renewed impetus once the MAPS delivery group is operational in late summer 2019. Check back here regularly for a summary of the latest position and expert views on what it means for you.
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.
As the MAPS delivery group (see ECOSYSTEM above) undertakes user testing later in 2019 and into 2020, the dashboard data requirements on schemes will become clearer. 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 takes effect in the early 2020s.
Schemes are likely to rely heavily on their in-house or third-party pensions administration (TPA) functions in order to help them comply. They would do well to engage early with their TPA or administration software supplier to understand their plans for supporting their clients with dashboard compliance.
The most proactive and forward-looking schemes and providers may not want to wait for compulsion. The MAPS delivery group is asking for schemes and providers to volunteer to join the dashboard ecosystem early, prior to compulsion applying. This will be a great chance to help influence the shape of the overall ecosystem, and the underlying data standards, for the eventual benefit of all UK citizens.
What’s next? Continue with your existing data management programmes and engage with your TPA / software supplier to understand their plans. ITM already helps many clients with their pensions data issues. Contact us to find out more and keep checking back here for the latest dashboard news.
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