An end-of-term report on pension dashboards

Many people remember David Cameron’s then-chancellor George Osborne asking the pensions industry to develop a prototype pensions dashboard, which the industry then unveiled to ministers in April 2017. 

What is less well remembered is the October 2017 industry report back to government, by then led by Theresa May, listing the 10 essential things that government must do to make dashboards a reality. 

Those 10 essentials remain true, so are a good yardstick to measure the government’s progress on dashboards over seven years, and to reflect on what incoming ministers need to do. 

The end-of-term dashboards report

Total score: 6.5 out of 10. Okay, but not great. That said, in that time there have been four changes of prime minister, two general elections, a protracted exit from the European Union, and a pandemic.

There has been progress, in some areas considerable, but many of the 10 essential actions remain incomplete. It’s up to whoever wins on 4 July to finish the job for UK consumers.

Progress against the 2017 dashboard actions

This table summarises my scoring, with detailed rationale for each action’s score explained below.  
 

Action 1: Deliver a government dashboard (score = ½)

MaPS reported in April 2024 that “the MoneyHelper dashboard project is progressing … working to ensure [it] is ready for testing at the earliest opportunity”. This scores ½ as it is a work in progress.

New government prediction: All parties support a “public service dashboard” so will likely want MaPS officials to push on rapidly with the delivery of the MoneyHelper pensions dashboard.

Action 2: Enable commercial dashboards (score = 1)

Primary legislation was made by Boris Johnson’s government, then secondary legislation by Rishi Sunak’s, creating the legislative provisions for commercial dashboards.

Treasury legislation was made in 2024 making “operating a [qualifying] pensions dashboard service” (referred to in the legislation as a QPDS) an activity regulated by the FCA. This scores 1 – well done! 

New government prediction: Commercial dashboards are supported by the two major parties. For example, the shadow economic secretary to the Treasury Tulip Siddiq said in January 2024: “Does the government expect commercial dashboards and the MoneyHelper dashboard to be available at the same time? […] To reach their potential, dashboards must be in services people already use [...] some commercial dashboards will present other financial data alongside pensions – one of the main benefits to consumers: to see all their finances in one place.”

Action 3: Regulate commercial dashboards (score = ½)

The FCA has worked hard here, but its work isn’t finished: there have been two FCA consultations on the detailed conduct rules for dashboard operators, but final rules aren’t expected until the fourth quarter of 2024.

From consumers’ and the industry’s perspectives, more collaborative work with the FCA is required to ensure these final rules strike the right balance between consumer protection and consumer utility. Once FCA’s rules are settled, the first operators might receive FCA authorisation some time in 2025.

New government prediction: The new government will likely want to press on fast to settle the right rules as soon as possible.

Industry: Meanwhile, the industry is ready to go on commercial dashboards, and has been for ages. One such dashboard has been available for two years, waiting for government to be ready to commence testing. Now, seven firms are preparing to launch their own dashboards, with many more firms expected to announce and join the independent non-commercial Pensions Dashboards Operators Coalition (PDOC).

Firms now understand that showing their customers all their pensions is just the right thing to do, especially in a post-FCA Consumer Duty world with a clear consumer understanding outcome. 

Action 4: Establish a delivery entity (score = ½)

In 2019, MaPS created the Pensions Dashboards Programme (PDP), formerly the “Industry Delivery Group”. But PDP only covers the central architecture (see Action 5) and standards (Action 9). This is why the National Audit Office (NAO) investigation report in May ignored collaborative delivery of dashboards (1-3 above) and data supply (8-10 below). Due to its limited scope, PDP scores ½.

New government prediction: The Personal Accounts Delivery Authority (PADA) was a previous collaboration between government and industry from 2007-10, set up to establish what became Nest.

Former PADA chair Baroness Jeannie Drake commented: “The people in PADA played a significant role building NEST […] recruitment of people from the private sector with the necessary expertise and cooperation between civil servants and private sector workers created the desired skill set for such an endeavour.”

My sincere hope is incoming new government ministers will generate a sense of cooperation at PDP just like existed at PADA over 15 years ago. Aiding that will be the leadership of new PDP senior responsible owner Iain Patterson, who was chief information officer for the London 2012 Olympics and Paralympics. 

Action 5: Deploy a central identity service (score = ½)

Despite the central identity service being probably the most critical component of the entire dashboards ecosystem, it appears this is where least progress has been made. PDP procured an interim identity provider in early 2022 (for which they score ½), but their long-term plans are unclear.

A blog post on UKAuthority.com in October 2023 reported that the DWP would bring dashboards onto the new GOV.UK One Login service from the autumn of 2024. One Login is committed to adhering to the key tenets of the UK digital identity and attributes trust framework. However, none of DWP, MaPS, or the Government Digital Service have confirmed PDP’s intentions for the central identity service.  

New government prediction: Digital ID is such a key component of the dashboards ecosystem we should expect the new government to push hard on resolving the above uncertainty urgently.

Action 6: Create a central digital architecture (score = ½)

PDP made a lot of progress in 2021 procuring the Capgemini/Origo consortium to deliver the different components of the central digital architecture, but then we had the programme reset in March 2023.

In the latest pensions ministerial statement in March 2024, the architecture is targeted to be ready for testing from August 2024. 

New government prediction: Incoming ministers will undoubtedly seek to maintain or hasten the pace of the central architecture testing with both data providers and, crucially, operators of actual dashboards.

Action 7: Agree an implementation plan (score = ½)

There is a partial plan and deadline, but it’s only that. In March, DWP published staged connection guidance for schemes setting out the timetable for them to connect to the architecture, spread out from April 2025 to September 2026, i.e. before the legislative deadline of 31 October 2026. But there is no published timetable and deadline for the testing and launch of dashboards to the public. 

New government prediction: The new government will want to urgently publish a testing and launch plan for dashboards so UK consumers can start to benefit from multiple dashboards as soon as possible.

Action 8: Compel schemes to provide data (score = 1)

Compulsion has been government’s main focus: primary legislation was made in 2021 requiring all but very small schemes to make their data digitally searchable.

Detailed regulations (for schemes) and rules (for contract-based pension providers) followed in 2022, then a revised connection timetable in March 2024. This is job done, scoring 1 – it’s just a shame it took six and a half years!

Separately, in November 2022, the Pensions Regulator consulted on its pragmatic Compliance and Enforcement Policy, but the final version is still awaited as of early June 2024.

Industry: There is now a flourishing market of technology providers (known as integrated service providers, or ISPs) preparing to connect their client schemes’ live data from April 2025. A total of 10 ISPs are in the PDP group of volunteer participant data providers preparing to test connections from August.

Action 9: Agree data standards with industry (score = 1)

During lockdown, PDP conducted an extensive call for input on data standards, leading to an initial version of data standards in December 2020. These were updated in November 2022 and then changed again in April 2024. It’s a score of 1, but these standards are untested with consumers.

Also untested on dashboards is the 2022 Financial Reporting Council standard for estimating future retirement incomes, updated for consistency across all defined contribution pensions. The industry was largely unhappy with the standard. Consumer testing in 2025 will show what they think. 

New government prediction: The new government will want to crack on as soon as possible with extensive consumer testing, collaborating with PDOC and the Pensions Administration Standards Association.

Action 10: Make state pension data available (score = ½)

The March 2024 ministerial statement said that “the programme plans to begin the process of connecting DWP state pension from August 2024”, but I haven’t seen any progress reports on this in the public domain directly from the DWP’s state pension team themselves.

New government prediction: The state pension is a core building block of people’s total income in retirement, especially for low earners, so the incoming ministers would want to push hard for early connection.

What’s left for the new government to do?

To move from 6½ out of 10 to full marks, the new government needs to:

• ensure MaPS delivers the MoneyHelper dashboard;
• ensure the FCA finalises its rules for dashboard operators and authorises firms;
• devise end-to-end collaborative governance for delivery of the ecosystem as a whole;
• ensure the Government Digital Service offers the right central identity service;
• ensure PDP connects data providers, including the DWP for the state pension; and
• make and execute a collaborative testing and launch plan for dashboards themselves.

We have come a long way since 2017, not least the making of historic legislation compelling all pension schemes and providers to make their members’ or customers’ data digitally searchable.

The new government must now finish the job, enabling multiple dashboards to be launched as soon as possible, with millions of working age UK consumers reaping the benefits for decades to come.

Richard Smith is volunteer chair of the Pensions Dashboards Operators Coalition.