On the go: New guidance from the Pensions Administration and Standards Association encourages all schemes to begin preparing for the introduction of the dashboards straight away, after the passage of the Pension Schemes Act set a series of events in motion.
The act, having received royal assent, means that the Department for Work and Pensions is free to consult on detailed dashboard regulations, PASA stated, while the Pensions Regulator and the Financial Conduct Authority can begin helping schemes and providers comply with their dashboard obligations.
The Pensions Dashboards Programme is now expected to publish its own detailed instructions on individual schemes’ and providers’ obligations to dashboards, and so standards and data exercises should be put in place now to smooth the transition, the PASA guidance noted.
PASA is shortly to publish more guidance on data management plans, but in the meantime its advice to schemes and providers is to put in place strategies for the “continuous high-quality maintenance of all your pensions data”.
Data management plans should include compliance with the regulator’s requirements, regularly reporting data quality measures as part of TPR scheme returns, “handling all regular interfaces from employer HR and payroll data sources, including exceptions”, and one-off, data-related exercises such as guaranteed minimum pensions equalisation and McCloud remedies.
While none of this is new information, PASA’s guidance noted that the data must now be stored in a way that is compatible with pensions dashboards, able to be digitally matched and returned for display on whatever dashboard a member chooses to use.
Schemes currently undertaking data work around GMP equalisation or implementing McCloud remedies should use that as an opportunity to bring their data into compliance with the dashboards, the guidance continued.
It stressed there is “no benefit in waiting” — despite dashboard compliance not being required before 2023, work should be done now to prepare for their introduction. Data exercises always take time, so beginning early will be crucial.
The first step should be to conduct an organisation-wide exercise to determine whether any records remain undigitised. The digitisation of records should be a top priority, the guidance stated.
Schemes will be able to voluntarily onboard in 2022, which will allow them to test their systems and standards before the compulsory sign-up in 2023.
Chris Connelly, chair of the PASA Dashboard Working Group, said: “Almost every aspect of managing a pension scheme is easier to achieve if you actively manage data. A good strategy will incorporate both ongoing and one-off scheme-specific data activities.
“Pensions dashboards, if done well, could be a game changer in getting people to engage with their pensions, and a better efficiency of pension scheme management full stop. As an organisation, PASA wants to play its role in ensuring the industry is as supported as possible in getting things ready and compliant.”
