Dashboards: Act now so we don’t have to, says TPR

The regulator has published its compliance and enforcement policy for pension dashboards, setting out areas of focus including trustees’ responsibilities for overseeing third-party service providers.

Its policy stated that “where we see wilful or reckless non-compliance, we will take a robust enforcement approach”.

TPR will engage with “hundreds” of schemes this year to analyse how they are getting their data ready for dashboards and will take regulatory action if schemes are “failing to meet our expectations”, said Nina Blackett, interim executive director of strategy, policy and analysis at TPR, in a blog post.

However, Blackett emphasised that the regulator would take a “risk-based and proportionate” approach.

“Our goal is to help schemes take the right steps now, so they are ready with the right data, ready for the dashboards switch on, ready to help make a significant impact on the saving outcomes of millions of people,” she said.

“If schemes prepare properly then we are less likely to use enforcement action to ensure they do the right thing. Act now, so we don’t have to.”

The regulator’s announcement comes after former pensions minister Guy Opperman warned that data was a “fundamental problem” that needed to be solved for dashboards to succeed.

Preparing for connection

The first deadlines for connecting to dashboards are scheduled for the second quarter of next year. Blackett said that, while many schemes were preparing correctly, there were still some that were “not measuring their data or trying hard to improve it”.

She urged trustees and scheme managers to read the guidance issued by the Department for Work and Pensions and ensure they know what their duties are under the law. They should also plan their connection in plenty of time before their deadline and manage resources appropriately.

To aid with preparations, TPR has published a checklist of tasks to help trustees prioritise dashboards and get ready for connection to the dashboard ecosystem in a timely manner.

On data management, the regulator expects schemes to “review and improve” member data quality and put in place processes to do this “continuously” to ensure ongoing compliance.

Schemes also need to effectively manage dashboard-related risks such as data protection and cybersecurity, even when these are delegated to a third party. Any breaches must be reported and mitigated promptly to “reduce the of further harm to the scheme and possible regulatory action”.

Regulatory interventions

TPR’s work on dashboards will focus on “where we see behaviours or breaches that endanger savers’ access to complete or accurate pension data”, Blackett said.

“Examples will include schemes failing to find a pension for a saver, returning data to the wrong saver (or inaccurate data to a saver), and failure to connect on time or stay connected, in accordance with the regulations and the Money and Pensions Service standards,” she explained.

“Timely action is essential,” Blackett continued. “Trustees and scheme managers must grip their obligations diligently and work closely with their providers to avoid the pitfalls of last-minute risks. We expect third parties to support schemes with these tasks.”

Jon Pocock, pension dashboard delivery manager at Broadstone, said: “Today’s update from TPR is a clear indicator that it expects pension scheme trustees and managers to be proactive as they prepare for the implementation of pension dashboards.

“Rather than wait for enforcement action, TPR has urged schemes to make data improvements to help connect to the infrastructure. The pension dashboards programme was always going to require a collaborative cross-sector approach, and we believe it is fair that schemes take these steps to support the financial wellbeing of their members.”

Further reading

Data remains ‘fundamental problem’ for dashboards, says Opperman (4 September 2024)

Trafalgar House warns of admin ‘tech debt’ (6 August 2024)

‘Capacity crunch’ risk as schemes failing to plan for dashboards (18 April 2024)

The Dashboards Nine-Nine series

1)        How Nest is preparing for connection day

2)        What Scottish Widows’ app tells us about the future of dashboards