An industry win on dashboard connection regulations

But, as they say, good things come to those who wait – and this transformational tool will definitely be worth the wait. 

As we move closer to the first cohort of connections to the dashboards architecture there has been a steady hum of activity taking place throughout industry in preparation, including at the Association of British Insurers (ABI).

Our engagement with the Financial Conduct Authority (FCA) has helped to secure a recent policy win so that more data can be connected to the central dashboard sooner rather than later, accelerating the industry’s efforts in launching this revolutionary service.

The problem

The FCA regulations previously required all connecting firms to upload 100% of their books at the point of connection. However, many firms across industry hold a small percentage of more complex business that will take longer than the bulk of their books to prepare.

Based on the regulations, this small percentage could hold up the connection of the bulk of a firm’s books, putting many at risk of connecting later than their connection date.

To progress towards the point at which dashboards become available, it is necessary for as much data as possible to be connected to the central digital architecture – both to allow user testing at scale and to have sufficient coverage across the market.

Firms could initially circumvent these rules by stating their case in a waiver to the FCA. This is a lengthy document, with a response time of six months and no guarantee of success.

The uncertainty became a huge barrier to connection for wider industry, and to that end we called for the FCA to amend these regulations to allow dashboards to become a reality as quickly and efficiently as possible.

The solution

After lengthy conversations and evidence submissions, the FCA has published a modification of consent, adjusting existing dashboards rules so that firms can use a flexible data-upload approach to connect to the pensions dashboards digital architecture.

This is a time-bound modification running from the time of publication to 31 October 2026 (the legal connection deadline). Colloquially referred to as a ‘blanket waiver’, firms do not have to apply for the modification, instead they simply notify the FCA and this will be placed on their FCA record.

Those firms that abide by the modification will be able to connect to the dashboards architecture once the connection window opens and upload a portion of their data in one go, while having the flexibility to finalise smaller pockets of business.

The FCA are asking for firms to aim for 80% coverage at the first stage of connection. However, this is not a hard line in the sand and many firms will choose to upload more, so long as 100% of books are connected by the 31 October 2026 legal deadline.

Impact on delivery

This not only incentivises firms to connect data earlier, but it means that large scale consumer testing with real data can take place more quickly.

Before the modification was granted, many firms ran the risk of not meeting their connection dates in guidance. This would have delayed user testing and, ultimately, the launch of these much-anticipated dashboards to the public.

Having this modification of consent removes what was a huge barrier to connection and creates the flexibility for schemes to work with the government and regulators to enable a faster connection for firms.

It is another welcome step to ensure the smooth launch of pensions dashboards, which we hope to see become a reality as soon as possible.

Emily Mae Collins is long-term savings policy adviser at the Association of British Insurers.