Pensions Dashboards – Later is 31 October 2026
The Government has laid draft Regulations before Parliament to “re-set” the timescales for staging and onboarding for pensions dashboards. There is now to be one single connection deadline for all schemes of 31 October 2026, with a revised staging timetable to be published in guidance. The additional time is to enable the successful connection of a wide range of different IT systems to the dashboards digital architecture.
Although 2026 seems a long way off, there is still a lot to do to ensure compliance with the pensions dashboards requirements so trustees should still be considering, with their administrators, the actions they may need to take now.
Pension dashboards are intended to allow individuals to view information about their pensions, including the State Pension, in one place online. Our March Newsletter (Pensions Dashboards – ready or not, they’re coming (albeit later!)) provides detail about the key takeaways for trustees following the Pensions Dashboards Regulations coming into force on 12 December 2022.
What is changing?
Following the proposed changes set out in the draft Regulations, which will amend the Pensions Dashboards Regulations, the pensions dashboard framework will not be changed. The draft Regulations are primarily to “re-set” the timetable for staging dates (i.e., the date by which a pension scheme must connect to the pensions dashboard system). Currently different schemes have different deadlines to meet, with the first connection deadline being 31 August 2023. Now it is intended that there will be one single connection deadline for all schemes of 31 October 2026, with a revised staging timetable to be published in guidance.
The draft Regulations also potentially change which schemes must comply with the Pensions Dashboards Regulations. This is because the current Regulations apply to all schemes will 100 or more active and/or deferred members as at the scheme year end date which falls between 1 April 2020 and 31 March 2021. However, the date for determining whether the Regulations apply to a scheme or not, under the draft Regulations, is to be applied as at the scheme year end date falling three years later, i.e., between 1 April 2023 and 31 March 2024.
Another key change the draft Regulations propose is that trustees will have to have regard to guidance from the Secretary of State. Therefore, it seems that, in additional to being aware of the legal obligations, trustees will need to have regard to guidance on connection published either jointly or separately by the Money and Pensions Service, The Pensions Regulator and/or the Secretary of State. Typically, guidance is not in itself legally binding but there will be a legal obligation to have regard to connection guidance in the legislation and trustees are unlikely to be able to comply with their legal obligations without taking account of the guidance. Therefore, trustees should seek advice on what they must, and should, do in order to comply with their pensions dashboards obligations.
Trustees should also work urgently with their administrators to ensure that scheme data is fit for purpose and complies with the expected data standards. This includes budgeting extra costs and resources, and taking appropriate advice on the various decisions that the dashboards require.
More detail and suggested actions can be found in our March Newsletter (Pensions Dashboards – ready or not, they’re coming (albeit later!)), here.