Data provider readiness
As a programme, we remain committed to supporting data providers with what they need to do to ready themselves for onboarding. We are entering an exciting stage of development as we begin the work to build the pensions dashboards ecosystem and enter our alpha stage of testing.
Together with DWP, TPR and FCA, we are holding quarterly meetings with industry bodies, such as the Association of British Insurers (ABI), the Pensions Administration Standards Association (PASA), the Pensions and Lifetime Savings Association (PLSA) and the Society of Pension Professionals (SPP) to ensure open dialogue between the programme, our delivery partners and industry. The meetings are a valuable opportunity for us to update the industry on our progress and to receive feedback relating to any opportunities or challenges that this presents the industry.
We recognise data providers are at different stages of readiness, with some committed to early connection as part of testing our digital architecture, while others are yet to start preparing to onboard. The call for input we issued in May provided the first indication as to likely compulsory staging dates but we would urge all providers to get ready to connect to dashboards as soon as possible, as there are many benefits to early staging.
Data providers hub
To keep data providers informed about what they need to do to ready themselves for onboarding, we have created a data providers information hub to hold all the vital information that they will need to prepare, including steps to connection plus further explanation of the pensions dashboards ecosystems.
In our last update, we reported that we were working with the pensions industry to encourage providers to onboard early to the pensions dashboards ecosystem, as part of our testing phases.
In July, we announced that seven organisations have agreed to work with us during the initial (alpha) testing phase of the programme. The organisations include software providers, insurers and third party administrators. Collectively they provide software or pension administration solutions to a broad range of public and private sector pension arrangements, covering defined contribution, defined benefit, hybrid and regulated pension provision. We’re very excited to be working with those providers.
The participating providers are:
Legal and General
During initial testing, PDP will work with these organisations to:
- develop dashboard technology
- ensure that its processes make onboarding as easy as possible
- share the learning that it derives from this work across the pensions industry, to help all providers to prepare for connection to dashboards
This initial (alpha) phase of testing will begin in December 2021 and will continue until June 2022. At the end of alpha, the participants will transition into beta testing, with live data. At that point we will invite other organisations to join subsequent testing phases.
We anticipate that the experience gained through the initial alpha testing phase will enable subsequent testing participants to progress more quickly through the process and help create a proven and efficient onboarding approach.
Call for input on staging
Staging refers to the process by which pension schemes and providers will be compulsorily onboarded to the ecosystem, as a consequence of DWP regulations and FCA rules.
PDP issued a call for input (CFI) on staging, which ran from May 27 to July 9, following our work with our regulatory and government partners to develop an initial set of draft recommendations on how staging might work.
The recommendations were not a formal legislative proposal but formed a valuable exercise, to gather key stakeholders’ feedback, evidence and insights, to help inform government and FCA policy development. The recommendations aimed to achieve the widest possible coverage, as quickly as possible, while taking into account the practical constraints and circumstances within the industry as well as regulators’ and PDP’s capacity limits.
We proposed that staging should take place over three waves:
- wave one, from April 2023: occupational schemes with 1,000+ members and FCA regulated providers of personal and stakeholder pensions
- wave two: medium occupational schemes (100 to 999 memberships)
- wave three: small and micro occupational schemes (99 or fewer memberships) This approach would achieve connection of 99% of pensions in scope for dashboards in the first wave, within two years.
There was broad agreement with the proposed sequencing for schemes and providers to be connected into the ecosystem, together with a prevailing view that the overall proposed approach is logical and reflects the policy objectives and staging principles well.
However, several respondents indicated that the timeline may be too ambitious, with most respondents indicating their lead-in time would start from the point of sufficient certainty (ie regulations in place) and full technical specification. We issued a summary of the CFI responses, which contains a full breakdown of the responses. Key areas of feedback included:
Estimated retirement income (ERI)
Use of integrated service providers (ISPs)
We’re working with government and the regulators to feed the evidence and insights gathered from the CFI into staging policy development, ahead of the DWP’s consultation this winter, and the FCA’s corresponding consultation on rules.
It is ultimately for the government and regulators to determine the staging approach and legislative framework. PDP will be paying close attention to the draft regulations and, once published, assess how that may impact on our planning and testing approach, particularly for those data providers that choose to stage early.