The UK’s Department for Work & Pensions (DWP) has today opened a further consultation into the Pensions Dashboards Regulations 2022.
The purpose of this consultation – which follows the first consultation launched in January – is to seek views on two elements of the draft and on a further supporting measure, it was announced.
The two specific issues that were not included in the January consultation are:
- The Dashboards Available Point (DAP);
- Proposals to support the Disclosure of Information between the Money and Pensions Service (MaPS) and The Pensions Regulator (TPR).
According to the DWP, the DAP is the point at which pensions dashboards services, as provided for in the regulations, will be made available to all members of the public.
“This will be at the point at which we believe sufficient progress has been made to demonstrate that pensions dashboards can begin working to meet our stated objectives,” the consultation statement said.
“The DAP is not a new concept. It is one that we have communicated publicly as proposals for pensions dashboards have developed,” DWP said, adding that it received a range of feedback on the subject.
For the January consultation, respondents noted that the DAP must be carefully selected and that they would value more certainty around the DAP to ensure schemes are prepared for an increase in queries, making sure they can cope operationally and can effectively manage communication to their members.
DWP is ‘missing the point’
According to LCP partner Steve Webb, however, who interprets DAP as being the ‘go-live’ date to the public, DWP is “missing the point”.
According to the consultation, Webb said, DWP will not finalise the go-live date until certain conditions have been met in terms of coverage and evidence of user understanding and experience, though some broad indication will be given as to the likely date.
“When it finally decides, DWP proposes that schemes may have as little as 90 days’ notice of the final go live date,” he stated. “Current expectations are that this may be in summer 2024, though there has yet to be any official indication of the intended date.”
Although the consultation makes brief mention of the suggestion of a phased go-live, there is no indication that DWP is planning anything other than a ‘big bang’ switch on, albeit following a period of extensive ‘beta testing’, Webb continued.
He said that a sudden switch-on of dashboards could cause huge headaches to pension schemes and pension providers and could also be a negative experience for users. With a ‘big bang’ switch-on, the dashboard infrastructure could face a huge ‘surge’ in demand, needing much greater capacity and resilience than would be needed for a more gradual process.
In addition, once users see their data it is likely to lead to a surge in queries to schemes, which may not be able to cope with the demand.
“Pension schemes may face real challenges in dealing with all the follow-up queries and engagement from members. A phased approach, perhaps by age, would be much more sensible, allowing the whole system to bed in and proper plans to be made.”
Karl Lidgley, client manager for third-party administration at Hymans Robertson, said that the 90-day goal does not provide enough scope in the current climate to match resource requirement to meet anticipated demands.
“There is not capacity in the industry to deal with the extra member engagement that dashboards are likely to generate for administrators, profitability is tight and resourcing to meet these needs, at 90 days’ notice, will be almost impossible in the current recruitment market.”
He added: “We would encourage the DWP to work with providers, in a live environment, as part of a trial launch to make sure full testing takes place and effective functionality and timescales are imbedded, prior to a full market launch to minimise disruption and ensure the industry is ready.”