Pensions Dashboards Programme

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Pensions Dashboards ProgrammeProgress Update ReportApril 2021

About usThe vision of the Pensions DashboardsProgramme couldn’t be simpler: “toenable individuals to access their pensionsinformation online, securely and all in oneplace, thereby supporting better planningfor retirement and growing financialwellbeing”. Chris Curry, Principal of thePensions Dashboards Programme.Our role in delivering pensionsdashboardsThe Money and Pensions Service (MaPS)established the Pensions DashboardsProgramme team, led by Principal, ChrisCurry, to design and implement theinfrastructure that will make pensionsdashboards work.The Money and Pensions Servicewill develop a dashboard (the MaPSdashboard) as part of its function toprovide information and guidance onpensions, but other organisations willalso provide dashboards. We are workingclosely with industry, government and theregulators to maintain alignment.What is a pensions dashboard?Dashboards will provide clear and simpleinformation about an individual’s multiplepension savings, including their StatePension. They will also help them toreconnect with any lost pension pots.Read the full pensions dashboardsfeasibility report and consultation, and theGovernment’s response

Contents1Foreword42Executive summary63Programme overview84Partner organisation activity115Programme governance and assurance136Pensions dashboards ecosystem design187Defining a user centred service208Procurement of the digital architecture219Procurement of the identity service2310Onboarding strategy development2411Liability model and consumer protection2612Research and insight2813Communications update30

1Forewordfrom Chris CurryChris Curry was appointedin 2019 on a part-time basisas Principal of the PensionsDashboards Programme at theMoney and Pensions Service.Chris reports into Chair of theMoney and Pensions Service,Sir Hector Sants.Chris brings valuable expertiseand insight gained in his otherrole as the Director of thePensions Policy Institute (PPI)where he continues to workpart-time. Chris has workedon important projects suchas the Department for Workand Pensions Auto-EnrolmentReview Advisory Group in2017, where he was co-chairand led on providing advice onthe theme of contributions.In some ways it’s hard tobelieve that six months havealready passed since ourlast progress update report.As we collectively emergefrom lockdown, for what wehope will be the last time, it’sclear that we’ve made somesignificant steps forward inthe Pensions DashboardsProgramme. Far from standingstill, the last six months havebeen full of activity.The programme remains on track againstthe indicative timeline that we publishedin our last progress update report.With our procurement of the principaldigital architecture underway,and further work taking place ondeveloping an onboarding strategy, weare in the position to add further detailto this timeline, to enable industryto prepare for connecting with thedashboards ecosystem. We havealso undertaken invaluable marketengagement on the identity service,to support the final development ofrequirements prior to going to tender.“Chris CurryPrincipal, PensionsDashboards ProgrammeThe programmeremains on track againstthe indicative timeline that wepublished in our last progressupdate report.We have a new ProgrammeDirector, Richard James,who joined us at the start ofApril. Richard brings with himconsiderable experience ofleading digital transformationprogrammes, which convincedthe interview panel, he wasthe individual to take theprogramme forward.”

Pensions Dashboards Programme Progress Update Report April 2021“We have seen progresstoo from our colleagues at theDepartment for Work and Pensions,with the passing of the PensionsSchemes Act, which lays thelegislative foundations forpensions dashboards.”He has some big shoes to step into.Jamey Johnson was seconded fromthe Department for Work and Pensions(DWP) to lead the programme in March2020. He built upon the initial progressin engaging with the pensions industry,creating a timeline for our programmedelivery and took us through the deliveryof data standards for initial dashboards,to where we are today. I am extremelygrateful for his contribution to theprogramme and we all wish him the verybest in his new role with the national Testand Trace programme.In addition to seeing a change in ourleadership team, we have also seen theculmination of the huge undertaking todefine the requirements for our digitalarchitecture and gain the necessaryapprovals for its procurement in linewith the government requirements. Aprocurement of this size and complexityattracts a lot of attention. Thanks to thededication of the team, the approvalsprocesses we have undertaken haveimproved our approach and we arewell underway.We have seen progress too from ourcolleagues at the Department for Workand Pensions, with the passing of thePensions Schemes Act, which lays thelegislative foundations for pensionsdashboards. This marked a significantmoment for all of us, but is just the startof the legislative process.5We will be working hard with ourcolleagues in DWP throughout the restof this year to help them develop andconsult on the detailed regulations thatwill require industry to deliver the datarequired for pensions dashboards. Wewill continue to engage with industry onthese requirements and, working with theregulators, provide further guidance onhow best to get dashboard ready.No doubt the next six months will bringtheir own share of challenges but by thetime of the next update, we should haveawarded contracts for the majority of thedigital architecture, which will take us intothe next phase of the programme. Here’shoping for a smooth path out of lockdownand a productive summer for us all.Chris CurryPrincipalPensions Dashboards Programme

Pensions Dashboards Programme Progress Update Report April 20212Executive summaryPensions dashboards will help individualsview their pensions information online,securely and all in one place, therebysupporting better planning for retirementand growing financial wellbeing.The Money and Pensions Service(MaPS) set up the Pensions DashboardsProgramme in 2019, where we areresponsible for designing and creating thepensions dashboards ecosystem, whichcontains the digital architecture that willmake pensions dashboards work.We are also responsible for developingthe governance framework to support andenable the implementation and operationof pensions dashboards.MaPS is developing a pensions dashboard,and we anticipate that other organisationswill build additional dashboards.This is our third progress update reportand provides a summary of what we haveachieved since October 2020, when wepublished our last report.Summary of achievements 6digital architecture procurement –following approval from government,we have commenced our procurementof the principal digital architecture forthe pensions dashboards ecosystem.The procurement is underway and weexpect to award the contract withinthe next six monthsidentity service procurement – wewill shortly commence a separateprocurement exercise for the identityservice, which will verify dashboardusers really are who they say they are.This follows analysis of the industryresponse to our market engagementexercise and a further Call for Input inearly 2021 data standards – in December 2020,following extensive engagement withthe pensions industry, we publisheda set of data standards for initialdashboards, which split data setsfor find (the data that matched withrecords held by pension providers) andview (the information to be displayedon users’ dashboards) onboarding – our Head of Onboardinghas engaged extensively with industryrepresentatives, and continues to doso, as part of developing an onboardingstrategy. This includes working to identifythe first set of volunteer providers,schemes and administrators to helpdevelop and test the digital architecture“The Money and PensionsService is developing a pensionsdashboard and it is anticipatedthat industry will build additionaldashboards.” team building – we have successfullyscaled up the team to ensure thatwe can deliver the next phase ofthe programme. This has includedrecruiting key senior roles andtechnical expertise, including a newHead of Technology consumer protection – we havecontinued to develop our policythinking around consumer protection,as well as our understanding of whatthis means for the liability model developing user centred designstandards and service standards– in our working groups and research,we have worked on identifying highlevel user needs, establishing the userrequirements, creating personas andmapping current user journeys. Thiswork is ongoing

Pensions Dashboards Programme Progress Update Report April 2021 research and insight – we areundertaking a range of work to furtherdefine the pensions landscape, expandour evidence base and define user needs governance – our reportingstructure, including the steeringgroup, Board sub-committee andportfolio committee continue tooversee our progress. PDP is nowpart of the Government MajorProjects Portfolio (GMPP), managedby the Infrastructure and ProjectsAuthority (IPA), which brings increasedgovernment oversight communications – we issuednewsletters monthly, with additionalblogs, videos and news reportedon our website and social channels,whose reach continues to growprototype and carry out user testingto further define user needs andrequirements from dashboards work with our colleagues at theDepartment for Work and Pensions(DWP), the Financial ConductAuthority (FCA) and The PensionsRegulator (TPR) to support progresson secondary legislation, followingthe passing of the Pensions SchemesAct 2021 build the team, to ensure we havethe necessary skills and capacity todeliver the programme effectively work with the pensions industryand the regulators on creatingan effective, consumer-focusedonboarding strategy, which we willcommunicate as soon as possible,together with our delivery partners,to ensure that pension providersunderstand their obligations ensure that we engage with all ourstakeholders to communicate progresson an ongoing basis further streamline governance,working within the GMPP frameworkFocus and prioritiesOver the next six months, we will continuewith our digital architecture and identityservice procurement. We anticipateawarding contracts and having a supplierin place by October for the central digitalarchitecture, with the identity service tofollow in early 2022.We will also continue to: develop and share our thinking onconsumer protection and how thingswill get resolved if something goeswrong, including a liability model ensure users are at the heart ofeverything that we do. We will carryout an information architectureproject, to establish the taxonomy andsite navigation of pensions dashboardsfrom a user perspective. This will feedinto the standards that dashboardproviders will use work on design standards for pensionsdashboards develop a user experience (UX)7

Pensions Dashboards Programme Progress Update Report April 202138Programme overviewDependenciesDelivering the Pensions DashboardsProgramme is an exercise in collaboration.We are reliant on the contributions of ourdelivery partners, DWP, the regulators(TPR and FCA), not to mention the actionsof thousands of data providers, which allneed to ready their data for connection topensions dashboards.Our Portfolio Committee consists ofrepresentatives from PDP, TPR, FCA,DWP & MaPS. The role of the group is toraise awareness and enable discussion ofdependencies and risks that cut acrossthe responsibility/accountability of theorganisations. The Portfolio Committeemeets regularly to review progressand ensure a co-ordinated approach todelivering pensions dashboards.Timescales updateWe published our indicative phase planin October 2020. One of our key aimswas to provide our stakeholders with anearly indication of when we think theywill need to act. Notably, we set out ourview that compulsory staged onboardingwould begin in 2023. There’s more on ouronboarding strategy below.Since October, we have spent timedeveloping our plans and learning moreabout the complex landscape in which weare operating.We have further developed ourcommercial strategy. As a result ofthis, we identified the most suitableprocurement route for our technicaldelivery partner and procurementhas started. There’s more detail onour digital architecture procurementarchitecture procurement below, onpage 21.We have developed an updatedindicative programme timeline. Our overallphase plan still holds true but it containsan extra layer of detail. The timelineprovides a clear breakdown of what willtake place over the next six months, plusthe expected timing of key milestoneswithin later programme phases.

Pensions Dashboards Programme Progress Update Report April 202112345Programmeset-up andplanningDevelop andtest PhaseVoluntaryonboardingand ongoingtestingStagedOnboarding anddashboardsavailable pointTransitionto businessas usualfrom 2023from 2024Apr 20 - Sep 2021architectureprocurement starts(april 21)2021 - 2022identity supplieronboard (early 2022)identity procurementstarts (summer 21)Programmeliability modelidentity serviceintegrated (spring /summer 22)architecture supplieronboard (autumn 21)ecosystem governancemodel (oct 21)staging call forinput andarchitectureinformation update(spring 21)Pensionprovidersretirement incomeguidance update(summer 21)support model fullyready to assist withstaged compulsoryonboarding(autumn 22)test environment ready(early summer 22)consultation onregulatory framework(winter 21/22)publish technicalguidance to supportdata provider technicaldevelopment activity(winter 21)architecturescaling andperformancetesting(autumn 22)voluntary onboardingstaged compulsoryonboardingcommences(spring/summer 23)establishregulatoryframeworkearly voluntary dataproviders connected fortesting (spring 22)data providers undertake preparatory work for staged onboardingearly adopter test dashboard providerstesting with volunteerdashboard providers,including MaPS and acommercial provider(early summer 22)Dashboardprovidersecosystem open to authorised dashboard providersadditional volunteerdashboard providersjoin testing activity(autumn 22)publish guidance fordashboard providers(winter 21)dashboard designguidance fordashboard providers(winter 21)establishregulatoryframeworkongoing consumer testing / user researchConsumersconsumerprotection update(summer 21)early consumertesting (spring 21)testing with c2000users (summer 22)large scalecustomer testing(2023)9

Pensions Dashboards Programme Progress Update Report April 202110We recognise that data providers(ie pension providers, schemes,administrators, trustees and intergratedservice providers (ISPs) want morecertainty and detail around what they arebeing asked to do and when they will beasked to do it.Building the team“A key priority for the programme wasthe recruitment of a programme directorto lead the PDP on a long-term basis.Following an open competition MaPS hasappointed Richard James. He brings awealth of experience to the role gainedfrom 23 years in the public sector. Mostrecently, he was Programme Directorof the Northern Ireland Trader SupportService Programme. He previously ledthe implementation of digital personaltax accounts for HMRC. We’re alreadybenefiting from his skill and experiencein digital transformation.With an expanded leadershipteam in place we will be in a strongposition to deliver against ourambitious work plan for2021 and beyond.”We have published more information fordata providers, in line with the contents ofthe updated timeline about the steps dataproviders need to take, in order to prepareto connect to dashboards.As the timeline indicates, we will shortlypublish further information on technicalspecifications, which we developed aspart of our ongoing procurement process.We will also publish a Call for Input onstaging, with more detail on the proposedorder and timing of staging.Further detail is available on the timelinepage on our website.We are committed to providing as muchinformation as possible as soon as itbecomes available, to provide industrywith sufficient warning to preparetheir systems.Since October, we have continued to buildthe team. The aim is to attract the peoplewith the right skills for the programme asit continues to develop.In December, we welcomed Paul Nooneto the PDP as Head of Onboarding. Paulbrings over 30 years’ experience in thepensions and employee benefits industry.He is engaging with industry and workingclosely with the regulators to developa plan for those schemes that want tojoin the dashboard infrastructure on avoluntary basis, alongside identifyingpotential dashboard providers.In March, we were joined by JamesReardon as our Head of Technology.James has worked in technology for over15 years, as a business analyst, productand portfolio owner and consultant. Jameswill be responsible for ensuring that ourtechnology delivery partner meets designand service standards.With an expanded leadership team inplace, we will be in a strong position todeliver against our ambitious work planfor 2021 and beyond.In addition to strengthening ourleadership team, we have focussed onbuilding the wider team, recognising thatthe next phases of the programme willrequire a range of skills.

Pensions Dashboards Programme Progress Update Report April 20214Partner organisation activityDepartment for Work and PensionsThe Pensions Schemes Bill introducedin January 2020, achieved Royal Assenton 11 February 2021 and became thePensions Schemes Act 2021. It containsthe legislation needed to compel pensionproviders to make individuals’ dataavailable to them via dashboards.David Reid, Pensions DashboardsProgramme Head of Policy, reflected onthe new legislation in this blog.The Act allows for the creation ofmultiple dashboards, to provide scope forinnovation and help to engage a broadrange of users. Users will also be able toaccess a dashboard service that is publiclyowned, provided by the Money andPensions Service.“11later this year and lay draft regulationsbefore Parliament for debate in 2022. Thistimetable supports the delivery plan setout by PDP, which expects the first dataproviders to be compelled to make dataavailable to users via dashboards in 2023.DWP is working with the The PensionsRegulator (TPR), HM Treasury, theFinancial Conduct Authority (FCA) andPDP on the development of policy toinclude within the regulations. Thesewill focus on: data requirements, stagedonboarding, the compliance regime andconsumer protection.Ahead of the formal consultation, DWPis developing plans in conjunction withFCA, TPR and PDP to engage further withinterested parties on emerging proposalsthroughout the year.The FCAState Pension informationwill be included on pensionsdashboards, to give people acomprehensive view.”State Pension information will be includedon pensions dashboards, to give peoplea comprehensive view. DWP is alreadymaking the changes, alongside colleaguesin HM Revenue & Customs, to ensure thatthe infrastructure required to provide StatePension information will be in place aheadof the first publicly available dashboard.Fuller details of how the dashboardsinfrastructure will operate and howorganisations will need to makeindividuals’ data available to them viadashboards will be set out in regulations.DWP intends to consult on the proposedregulations for pensions dashboardsThe Pension Schemes Act requires the FCAto make rules so that compulsion applies tothe providers of personal and stakeholderpension schemes. These rules must takeaccount of the corresponding regulations theGovernment will introduce for occupationalpension schemes. When finalised, the FCAwill then be empowered to supervise andenforce against those rules.Subject to an amendment of theRegulated Activities Order by HMTreasury, the FCA will develop anappropriate authorisations regimefor organisations seeking to becomedashboard providers. The FCA willalso make rules governing the conductof authorised dashboard providers,to secure an appropriate degree ofconsumer protection.

Pensions Dashboards Programme Progress Update Report April 2021Before the FCA can finalise all thesenew rules, it will carry out a cost-benefitanalysis of, and consult on, draft rules.After finalising the rules, the FCA mustallow organisations an appropriate periodof time to apply for authorisation and/orcomply with them.5The Pensions RegulatorTPR will be tasked with regulating thecompliance of thousands of occupationalpension schemes, which in turn will relyon administrators, administration softwareproviders and ISPs to support them.It is bringing to bear its experience ofthe automatic enrolment programme andwill take a proactive approach to helpindustry meet its duties. The regulatorwill engage with industry as it preparesto comply and work collaboratively withboth industry and other delivery partnersto identify risks and develop solutions, tomake dashboards a reality. TPR is workingon designing this engagement programmeas a matter of priority so it can launch inplenty of time for schemes to get ready.The regulators working togetherWhile compulsion is not expected to beginuntil 2023, the regulators have beenlaying the groundwork by:12The Money and Pensions Service(MaPS) dashboardThe Money and Pensions Service wastasked by Government to create and runa non-commercial dashboard – the MaPSDashboard. A cross-departmental teamhas been working to make this happen.A key consideration for the team is thatonce people are able to see what theyhave in their pensions, this will triggerother questions in people’s minds. Thishighlights a need to help them betterunderstand what they have and how theycan use that information to help themplan for and in later life.The main focus for the MaPS Dashboardhas therefore been on mapping theconsumer journey, and developinginsight into the types of consumers whomight use pensions dashboards, theironward journeys and what they mightneed to enable them to support decisionmaking and, importantly help avoidpotentially detrimental decisions. MaPScommissioned initial qualitative userresearch to explore what consumerswould want to do upon seeing dashboardsto inform our customer journey design.The team intend to publish the results inthe summer. They will continue to workwith the PDP team to align their activity,especially around consumer needs. advising DWP on the design of thelegislative frameworkIn the coming months the MaPSdashboard team will start to develop: building a view of the systems,processes and data they need todeliver their roles their technology solution in line withthe expected infrastructure set out byPDP working with PDP on the developmentof the technological infrastructure so itsupports their compliance functions their consumer segmentation andjourney design establishing collaborative workingpractices with each other, and with PDP,to minimise the burden on industryand ensure those regulated by bothregulators are provided with consistentmessaging and coherent requirements. a roadmap for how they will deliverthe support and guidance they offerto consumers who use the MaPSdashboard

Pensions Dashboards Programme Progress Update Report April 2021513Programme governanceand assuranceChris Curry is the Principal and Senior Responsible Owner of the PensionsDashboards Programme. Chris has overall responsibility for making decisions aboutdelivery but he remains accountable to the MaPS Chief Executive and the MaPSboard, via a Sub-Committee.The Sub-Committee meets on a quarterly basis to hold the programme to account,direct its work and take investment decisions.The Portfolio Committee is now well established. It tracks progress on the majordependencies and is enabling effective coordination and cooperation across all the publicsector organisations involved in delivering pensions dashboards.Spotlight on Portfolio CommitteeThe Portfolio Committee is a cross-government group, with representatives from allof the delivery partners involved in the programme: Pensions Dashboards Programme Money and Pensions Service Department for Work and Pensions The Pensions Regulator Financial Conduct AuthorityIt meets quarterly to enable the effective management of the programme’sinterdependencies.David Fairs, who sits on the Portfolio Committee, writes the following:(NB: this is David’s personal view, rather than that of the PDP)“Bringing all the key players together in the Portfolio Committee is essential toensure the rollout of pensions dashboards is efficient and effective. It creates acommon understanding and commitment to the overall roadmap. It pulls togetherinformation from all of us so we have a coordinated view of delivery plans, butalso the risks to delivery - just as you would hope it would. This way we can beconfident nothing is falling through the cracks.“At the moment one particular topic of interest is staging – the order in whichschemes will be required to participate. The landscape is complex and whilst TPRcan look back at its roll out of Automatic Enrolment, in many ways that was a morestraightforward operation. With the pensions dashboards programme, there is muchmore complexity around types of scheme, administrator and industry preparedness.

Pensions Dashboards Programme Progress Update Report April 202114We need to balance the desire for dashboards to be operational at the earliestopportunity with the many competing demands on the pensions industry and itscapacity to provide complete, accurate and digital data. So these are the kinds ofissues we can explore and discuss as a group.“Pensions dashboards are a hugely exciting programme to be a part of, whichwill transform the provision of information and understanding of pensions inthis country. There are a lot of challenges to overcome but through the PortfolioCommittee we can challenge and support each other in equal measure, so we canall play our part.”David FairsExecutive Director of Regulatory Policy,Analysis and Advice at the Pensions RegulatorOur industry Steering Group continues to play a vital role in directing and assuring ourwork. The Steering Group is a strategic body, made up of pensions industry, consumerand fintech representatives. It is responsible for informing the design and delivery of theentire dashboards ecosystem.We want people to know more about the Steering Group members and the perspectivesthat they bring to the role. While all members will have their own individual viewpointsand priorities, some of which are not currently government, DWP, MaPS or PDP policy orpart of the programme, the range of views helps to inform and improve the programme.Spotlight on members of Steering GroupWe asked two of our Steering Group members for their take on contributing to theprogramme – individuals on the Steering Group have differing views and it is this mixof opinion and oversight that allows us to navigate the different requirements of ourstakeholders. Please remember, these are their personal views, rather than that of thePensions Dashboards Programme, Government, DWP or MaPS.Sam Seaton, Moneyhub CEO, commented:“It’s been nearly a decade since mandatory contributions were introduced,and while this was a positive move, we missed a trick not legislating atthe time that information on an individual’s pension pots must be visible,available and easily accessible. Fortunately, we are now heading in theright direction, and the implementation of pensions dashboards willbe a huge leap forward. Falling at this hurdle is simply not an option –consumers need and deserve the initiative to be a success.“I’ve advocated for the consumer throughout my career, so being a part of the PDPSteering Group is immensely rewarding. Having the opportunity to help challengeand secure the necessary change to enable the full potential the project can achieveis very dear to me.

Pensions Dashboards Programme Progress Update Report April 202115“I am passionate about harnessing the power of digital innovation to transformfinancial wellbeing. The outlook is hugely positive and 2021 is already set to be apivotal year for pensions dashboards. Development continues, building towards thevoluntary onboarding and testing with pension schemes and providers next year.2023 sees the compulsory rollout, so momentum really is building and I can’t waitto see the final results. Pensions are a fundamental part of successful long-termfinancial planning. It is essential that we make it simpler for consumers to takecontrol of their future, and I’m delighted to be part of that transformation.”(NB. this is Sam’s personal view, which is not representative of the programme as a whole)Dominic Lindley sits on the Steering Group as an independent financial consultant.He gives us his personal take on supporting the programme activity and where hewould like to focus:“Pensions Dashboards could help savers engage with their pensions,providing new insights that help them manage their money,prompt them to seek guidance or advice and provide access to newproducts and services.“To make this happen, consumers need clear rights to theirfinancial data, a body to set technical and data standards intheir best interests and strong regulation of intermediaries using this data toprovide services. The welcome royal assent of the Pension Schemes Bill andforthcoming DWP consultations will help deliver the first of these. The PensionsDashboards Programme is making progress developing the data standards andis starting a conversation about the framework for consumer protection.“We need to learn important lessons from Open Banking but also acknowledgethe differences and extra challenges. Open Banking only covered the nine largestbanks, dashboards cover large providers and hundreds of smaller schemes. In OpenBanking, all of the information is already digitalised and connected and there is aneasy way

Contents Foreword 4 Executive summary 6 Programme overview 8 Partner organisation activity 11 Programme governance and assurance 13 Pensions dashboards ecosystem design 18 Defining a user centred service 20 Procurement of the digital architecture 21 Procurement of the identity service 23 Onboarding strategy deve

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