The Pensions Dashboard project: slowing down or accelerating towards implementation
The introduction of an online pensions dashboard, enabling users to see all their pensions savings information electronically in one easily accessible place, has been eagerly awaited following its original announcement in 2016. However, with the once anticipated 2019 implementation date now long gone, where does the project currently sit?
The Pensions Dashboard Programme (“PDP”) recently released its inaugural Progress Update Report and now intends to provide updates every six months. The report highlights, in several places, the impact of Covid-19 on the project. The Report predominantly focuses on what the plans are going forward, as opposed to detailing progress that has already been achieved. However, this blog will touch on both.
First, a summary of what has been achieved so far. The Progress Update Report:
- confirms that a Steering Group has now been established to represent the interests of both consumers and stakeholders within the pensions, financial services and fintech sectors; and
- sets out details regarding the type of information that pension savers might expect to access through the dashboard, which is helpful.
Additionally, the publication of two working papers on Data Definitions and Data Scope, alongside the Progress Update Report are helpful in terms of setting out the options for achieving comprehensive coverage across all pension sectors, and scoping out the data items that could be included in the dashboard’s data standards, both key priorities of the PDP over the next 6 months.
A further positive can be taken from the PDP’s view that, even if only a relatively small number of large pension providers were to join the dashboard initially, this would ensure that a significant proportion of pension entitlements would be available to individuals via the dashboard relatively quickly. Assuming this does in fact happen in practice, it is hoped that this will mitigate and diminish the impact of delays to implementation. The Report seems to indicate that the dashboard will be made available in stages, with consumers able to start using it in some format, even if all of the identified issues have not been entirely resolved.
Now to the rather longer list of tasks still outstanding before the dashboard can be implemented: the Report readily admits that implementation of the dashboard is constrained by several dependencies and challenges. In particular, it lists legislation, data quality and matching, provision of an identity service and the development of the Integrated Service Provider market, as key issues. The level of detail afforded to each of these issues in the Report only emphasises just how much still needs to be done to overcome them. Nevertheless, the Report does offer some reassurance that the next 6 months will be spent focussing on resolving these issues and on the key dependencies needed to ensure successful implementation.
These issues alone present a number of challenges but it is interesting to see the PDP’s acknowledgement that some of these issues cannot be resolved by the PDP alone. From a legislation perspective, the PDP is waiting for the DWP to determine the basis on which pension schemes are legally required to engage with the dashboard; this is still being debated by Parliament. Much of the detail will be in secondary legislation, together with rules and guidance to be issued by the FCA and the Pensions Regulator in due course. When it comes to building the dashboard itself, the PDP is relying on other organisations to provide the digital architecture that is needed, and once that is available, there will be a whole workstream of user testing and user acceptance which will entail considerable input from third parties.
Of interest is the fact that the Report makes reference to examples of dashboards that are already in force internationally and lessons learned from those, in particular the importance of defining the scope of data standards from the outset.
A task too great?
Noting then, in the PDP’s own words, “the scale of the challenge” before the dashboard can become a reality – is it possible that the task could prove too great? Unlikely. Although the Report acknowledges that delivering the dashboard is a “significant undertaking”, it confirms that the PDP remains committed to doing so and is looking to provide a clear delivery timetable with dates as soon as possible, acknowledging that there is a strong desire for this across the industry. We look forward to the next Progress Update Report in 6 months’ time, and in particular look forward to the much needed clarity around the precise timeframe for implementation.