The Government has published its response to its Pensions dashboards: consultation on the draft Pensions Dashboards Regulations 2022. The tone is set in the introduction where Guy Opperman, the recently reinstated Pensions Minister, notes “The important point readers should take away from our consultation response is that the Government remains fully committed to making pensions dashboards happen at the earliest opportunity … . Trustees or managers of pension schemes of all types and sizes should therefore focus their preparations on making sure their data is ready and they have plans in place for how they intend to connect to the digital architecture”.
The response confirms that the staging dates will be tweaked by:
The response refers extensively to the Information Commissioner’s Office’s response. This encourages schemes to produce/update their Data Protection Impact Assessment with regard to the process for matching data received from the dashboards ecosystem with that held in the scheme.
Most respondents asked for a widening of the criteria for deferring the staging date. The response indicates that the DWP will provide some easements for schemes in PPF assessment or that are winding up, but otherwise there will be no changes. However, here as elsewhere, the response notes that The Pensions Regulator (TPR) has discretion as to how to enforce the requirements.
The Regulations themselves have not yet been published. This is unsurprising given the separate ongoing consultation on matters that will feed into the Regulations (Dashboards Available Point and exchange of information between the Money and Pensions Service (MaPS) and TPR). While the response notes that the Regulations will be amended, it is silent on a timetable for when they will be laid before Parliament. In a number of areas, for example the simplified approach for the calculation of deferred DB benefits, the response gives insufficient information for schemes to be able to take action.
Finally, MaPS is expected to consult on data standards shortly with TPR consulting on its compliance and enforcement policy once the Regulations have been laid before Parliament.
