On the go: The Pensions and Lifetime Savings Association, while “fully supportive” of the goals of the Pensions Dashboards Programme, has argued that delivery against the proposed staging timeline appears ambitious.
The PDP published its call for input on staging at the end of May, seeking industry views on proposals for a three-wave implementation process. As reported by Pensions Expert, the latest call for input closed on Friday.
In its submission to the call, the PLSA said it strongly supports the goals of the dashboards, to help savers locate their pensions, increase their awareness of their different pensions by seeing them all in one place, and to help them take greater ownership of their financial provision for retirement.
However, because there are so many significant areas of uncertainty, assumption and dependency, PLSA said its members “find it extremely difficult, or are unable, to estimate how long they will need to be ready to connect to the central pensions dashboards architecture”.
“Therefore, we believe that the current PDP proposal that staging should start in April 2023 looks highly ambitious, as does the assumption that large defined benefit schemes should begin to stage around the end of 2023,” the PLSA stated.
The association agreed with the order of the staging set out in the call, noting that by starting with large master trusts and group personal pension providers, “PDP is likely to get a very large number of savers on to the dashboards very quickly”.
Under current plans, schemes with 1,000-plus members would be onboarded in a first wave, starting with master trusts and Financial Conduct Authority-regulated providers, which would begin to come onboard in spring 2023.
Defined contribution schemes used for auto-enrolment would begin onboarding later in 2023, while all remaining occupational schemes with 1,000-plus members would follow.
The PLSA added that in light of the mixed DB and DC provision of those most likely to use dashboards, it would make sense to try stage DB and public service pension schemes as soon as possible.
Uncertainty over the infrastructure with which schemes will have to work is problematic, according to the PLSA.
While its members are keen to comply and help make the dashboards a reality, their ability to do this is largely dependent on their existing administration system providers or third-party administrators being willing and able to act as their integrated service providers.
“No integrated service providers have yet connected to the dashboard’s central digital architecture; indeed, the architecture does not yet exist, nor has its supplier yet been procured,” the PLSA stated.
“Detailed technical specifications for the application programming interface that service providers must use need to be developed, tested and published.
“Any estimates for timelines are all based on the critical assumptions that the CDA is procured, built, tested, and API specifications published, and then ISP services are developed, connected and tested, including on key issues such as security and performance.”
The interaction of the new dashboards legislation and existing data protection law has also not yet been devised. This will be critical before any schemes can start meeting their dashboards compulsion duties, the PLSA pointed out.
To make the pensions dashboards a success, the PLSA believes there is a critical need for extensive testing of what most users can understand.
Only once this testing has been completed should the ‘view’ data be settled in the PDP standards, and only then can estimates be provided by the industry of the time needed to achieve connection.
Nigel Peaple, director of policy and advocacy at the PLSA, said: “The pensions dashboards have the power to transform savers’ awareness of their pensions and ultimately lead to better retirement incomes.”
He added: “However, even with the best endeavours of the pensions industry, there remain a number of significant areas of uncertainty, assumption and dependency that must be resolved before a firm timeline can be set for connection to the central pensions dashboards architecture.
“We are enthusiastic about pensions dashboards and will be offering as much support to the PDP as possible to resolve the identified issues, but a flexible approach to staging is likely to be needed.”
