The Pensions Regulator (TPR) has set out how it expects UK trustees and scheme managers to comply with their pensions dashboards’ duties, as well as the actions it will take for noncompliance.

TPR said its goal is to help schemes take the “right steps” now, so they are ready with the “right data, ready for the dashboards switch on, ready to help make a significant impact on the savings outcomes of millions of people”.

It added that if schemes prepare properly then the regulator is less likely to use enforcement action to ensure that schemes “do the right thing”.

Nina Blackett, interim executive director of strategy, policy and analysis, said: “Act now, so we don’t have to.”

She added that “before we know it” pension dashboards will result in a “huge wave” of savers interacting with their personal data. “Failure to meet your duties is therefore not an option,” she said.

Blackett acknowledged that many schemes are getting ready to connect in the “right way” with the “right data”, but she added that it “cannot be right” that there are still some schemes not measuring their data or trying to improve it with the connection dates approaching.

“That is why we will be engaging with hundreds of schemes this autumn, asking them to account for how they are measuring and improving their data. We may take regulatory action where trustees or scheme managers are failing to meet our expectations,” she warned.

Next steps

In order to prepare for the dashboard connection launch, the regulator said trustees and scheme managers should: 

  • Read the guidance – knowing their duties is the first step. In particular, the regulator will expect trustees and managers to be able to demonstrate their ‘having regard’ for the Department for Work and Pensions’ (DWP) connection guidance.
  • Plan to connect in a staged and orderly manner in line with DWP guidance. Schemes face increased risks of non-compliance and reputational damage if they don’t connect promptly.
  • Manage resources according to their plan. Trustees must establish robust controls and contractual agreements when selecting and managing service providers.

TPR also said ensuring that data is robust and accurate is an “absolutely essential” underpinning principle for schemes as they prepare for their connection to dashboards.

It wants schemes to review and improve the quality of data, manage risks, review and adjust controls that are in place, as well as keep robust records of decisions made and advice received.

In addition, TPR wants schemes to report and mitigate breaches promptly in order to reduce the risk of further harm to schemes and possible regulatory action.

Blackett, said: “Our compliance and enforcement efforts will focus on where we see behaviours or breaches that endanger savers’ access to complete or accurate pension data. Examples will include schemes failing to find a pension for a saver, returning data to the wrong saver (or inaccurate data to a saver), and failure to connect on time or stay connected, in accordance with the regulations and MaPS standards.”

She added that timely action is “essential” and trustees and scheme managers must “grip their obligations diligently” and work closely with providers to avoid the “pitfalls of last-minute risks”.

“We will carefully monitor and identify any risk of non-compliance. But we hope that for most, enforcement is not required. Instead, we encourage schemes to do the right thing now, and help savers reach the outcomes they deserve,” she concluded.

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