The dashboards consultation response: a positive step forward

Government consultations are peculiar things. Quite often they list the positive and negative feedback, stress that the issues are finely balanced, but having considered everything in the round they will proceed as originally planned — ie, because the government was right all along.

Reading through this response I get a sense of déjà vu, but that is probably doing the DWP a slight disservice as there are some interesting tweaks to the original proposals that will help schemes and providers in implementing dashboards. 

Like the original consultation document, the response is a considered and well-drafted document that sets out the arguments clearly.

We need to move away from the mindset that the dashboards are just digitisation of current processes and practices

If only all consultations and responses could be so clear. In the early parts of the consultation response there are some useful clarifications and tweaks to the proposed regulations based on feedback.

There is also a strong statement from the Information Commissioner’s Office about data quality and accuracy. The dashboards’ success (or not) will all come down to data quality, particularly matching, and schemes and providers have a massive job to do to get their houses in order on this.

Staging timetable delay was sensible

One thing that really sticks out in this consultation is the change to the staging timetable. The government has pushed back the timetable for two months for the staging of larger schemes and providers, eating into the proposed staging firebreak to ensure the overall dashboard delivery does not slip.

This is a sensible easement as the timetable is very ambitious, some might say unrealistic, even with this change.

It is now all about delivery and attention will focus on the Pensions Dashboards Programme’s readiness to onboard providers and schemes, and, importantly, the significant testing that will have to be done so we can be sure that the system is robust and behaves as intended. It is unlikely to be plain sailing.

Another easement is around allowing a simplified approach for deferred benefits for non-money purchase schemes. There is tension here between accuracy and timeliness, and the government’s approach of allowing choice for schemes — albeit a qualified one — is a sensible easement. Any projection is fraught with uncertainty, whether money purchase or non-money purchase.

There will need to be clear risk warnings and caveats regarding all projections. How this information will be displayed to dashboard users will be crucial to ensure people are using dashboards as intended and are not making decisions based on a false premise. User experience testing here will be crucial.

And then there are the issues related to public service schemes and the McCloud judgment, where the DWP will tighten the regulations. Yet another unintended consequence of public sector pension reforms — the gift that keeps on giving!

It is also good to see that the DWP is sticking to its guns on response times. Pensions need to be brought into the digital age, and in the digital age user experience and real-time information is crucial to delivering a positive user experience.

More than just digitisation

We need to move away from the mindset that the dashboards are just digitisation of current processes and practices. Over time I expect all schemes to move to a near real-time approach to providing information — and I recognise the considerable challenges here — as this will truly unlock the power of dashboards for the user.

The final point to highlight is that the DWP is not prohibiting the export of data from dashboards and leaving it for the Financial Conduct Authority to consider. This is positive, so long as allowing data export is done in a well-controlled and safe way.

Longer term, I am hoping that dashboards will go beyond “find and show” and allow more interactivity to help people plan. That will be a positive step to help people engage with their pensions.

There is a lot in this consultation response and I have only picked out a few of the highlights. No doubt the details will again be poured over when we get the final regulations.

But overall, it is a positive step forward in the development of dashboards and providing better pensions for scheme members.

Darren Philp is an independent pensions consultant