Pensions Dashboards

Pensions dashboard: Staging Call for Input May 202115.5In summary:Find and view data elementsfirst namesurnamedate of birthfind data(used to match usersto their pensions)current addressnational insurance numberprevious address(es)email addressmobile phone numberthe details of the pension arrangement in which theindividual has a pensionadministrativedatawhere available, the details of the employment thatgave rise to the pensionview data(data to bereturned tousers)7the details of the organisation administering thepension arrangementvalue dataan estimate of the annual income the individualmight receive in retirement (as per relevantguidance in disclosure regulations for DC; at leastone DB value with benefit calculation date), pluscurrent pot value for DC pensionsfurtherinformationsignposts to additional information about thepension (including costs and charges and otherinvestment information)The pensions dashboards ecosystem’s governance register is a technical service that provides assurances that the different elements of the ecosystem(dashboards, identity services, pension finder service and connections to pension schemes) meet the required standards to participate. It ensures that allthese elements operate correctly and securely. It will also enable compliance and monitoring of the system as a whole8The consent and authorisation service is a central service that manages user consents and authorises ‘find’ and ‘view’ requests. It will also manage theregistration of data providers’ and dashboards providers’ software

Pensions dashboard: Staging Call for Input May 202116.6We have also set out how the pensions dashboards digital architecture will work and what itwill require of data providers on our new data providers hub:RequirementActions register two interfaces (find and view)with the governance register7connect to theecosystem register software with the consent andauthorisation service8Further informationfurther detail, includinggovernance andtechnical standards willbe available via the PDPwebsite in winter 2021 comply with PDP service standards,specifications and technical requirements(including security and safety technology,notification and reporting requirements)comply withthe find andview interfacestandards ensure find interface and view interfacecomply with the PDP standardsFurther technical standardswill be available via thePDP website in winter 2021 receive find data from the pensionfinder serviceData standardsintroduction register automatic receipt (within a settime limit)Data standards guide run internal searchreceive andrespond to findrequestsdetail on the technicalrequirements is availableat the providers’ hub. any data received as part of the findrequest should be deleted once a matchhas been either made or not found if positive match, register a pensionidentifier (PeI) token (an encodedidentifier token for secure access, whichidentifies a found pension) and storeview data for subsequent access by userat dashboard (within set time limit) if partial matches, register PeI tokeninviting the user to contact the providerdirectly via email / phone / webform etc

Pensions dashboard: Staging Call for Input May 2021 implement the user managed access(UMA) specification, related to the roleof data providersdetail on the technicalrequirements isavailable within theArchitecture brief forsuppliers. Plus furthertechnical standards willbe available via the PDPwebsite in winter 2021 generate view data so that it can bereturned to dashboardsData standardsintroduction receive and acknowledge receipt ofview requests from users/delegates atdashboards (within set time limit)Data standards guideimplement theUMA profilereceive andrespond toview requests check view requests permissions againstthe consent and authorisation service if authorised, retrieve view data frominternal systems and transmit to beviewed on dashboardgovernance delete users’ data related to theecosystem on request or after asignificant period of non-use meet regulatory andmonitoring requirements17.7we are working withindustry and ourdelivery partners onthe presentation ofvalues and will issuemore informationon calculating andpresenting values insummer 2021further detail, includinggovernance andtechnical standards willbe available via the PDPwebsite in winter 2021This call for input concerns the question of when. In considering what our recommendationsfor when would mean in practice, we encourage industry to also consider the what (data)and how (digital architecture requirements) set out above.

Pensions dashboard: Staging Call for Input May 2021Call for Input questions:Find-only vs find-and-view dashboards18.One option to deliver a useable servicesooner, while also taking into accountdeliverability challenges, could be tophase compulsion duties to first requireschemes and providers simply to connectand register found pensions, and thenreturn value information (estimatedretirement income and accrued value) ata later date. This was proposed by somerespondents to our call for input on datastandards, published in summer 2020,participants in our qualitative researchwith pension schemes and providers andin some of our subsequent interactionwith the industry. It could support widecoverage of pensions findable earlier,achieving one of the policy aims fordashboards (reconnecting savers withlost pots), and potentially enabling publiclaunch of a ‘find-only’ dashboards serviceat first, with a full ‘find-and-view’service to follow.19.However, evidence indicates that adashboards service that found pensionsand returned contact/administrativeinformation but did not return informationon the value of these pensions, wouldlack credibility with consumers.Q1 to Q3: Responder details (see page 33)Q4: [Pension & data providers:] Basedon the information, how long do youestimate you will need to be ready toconnect, and why? From what pointin your working assumptions does thelead time start (eg draft regulations,regulations laid before parliament,or approved)?Q5: [Pension & data providers:] Ifdifferent from your response to Q4, howlong would it take you be able to provideall the required view data?Q6: [Pension & data providers] Wouldresponse time be material to onboardingie would longer response times for ERIor accrued value information (ratherthan real-time) facilitate earlier staging?If so, what sort of response time wouldmake a difference?Q7: What further information, if any,do pension providers need to get readyfor dashboards?8

Pensions dashboard: Staging Call for Input May 2021As the DWP’s pensions dashboardsfeasibility work and consultationconcluded, the question of ‘How muchdo I have/will I have?’ is a crucialcustomer need.9 Similarly, researchfor the Money Advice Service, foundthat respondents – without prompting– identified the ability to see all oftheir pensions values side-by-side asthe aspect of a dashboard that wouldhave the greatest potential usefulness,alongside locating lost pensions, andthe ability to view a forecast of annualincome.10 Further research found currentand projected value to be the mostpressing information for consumersand a major unmet need. This researchconfirmed current value as part of the‘bare minimum’ that people expect tosee, and identified a “low tolerance fora service that has limited informationabout their pensions, especially ifthere are no values”.11 Research byAJ Bell likewise found two-thirds of itscustomers would want dashboards toshow how much the pension is worthand what income it might translateto upon retirement – and over half(54%) said they would be less likely touse a dashboard that contained onlyinformation about some oftheir savings.1220.921.Based on this evidence and analysis,we have based our recommendationsfor staging on the assumption that theinitial dashboards service will requireboth find and view functions – butstaged in a way that addresses theindustry’s concerns about the readinessof some pension providers, giving thosewho are less ready to return view datamore time to prepare.22.However, this call for input provides anopportunity for stakeholders to provideevidence on whether the deliverability ofour recommendations would be materiallydifferent if initial dashboards were a findonly offering for a limited time.Q8: Do you have any further evidence onconsumer needs and/or the acceptabilityof a dashboards service displaying partialinformation for a limited time?DWP consultation, 201810ComRes research for the Money Advice Service, 2017112CV Research for the Money Advice Service, 201712Research by AJ Bell, 2019 (It should be noted, however, that this sample may not necessarily be representative of all likelydashboards users)9

Pensions dashboard: Staging Call for Input May 202110Developing a staging modelDashboards policy objectives23.The policy objectives for pensionsdashboards set out by government in theDWP’s 2018 Consultation are to:13Approach to staging24.The approach to staging needs toachieve a balance. It must achieve thewidest possible coverage – ie consumersbeing able to find and view theirpensions – as soon as possible. This isimportant to achieve before pensionsdashboards are launched to the public:research indicates consumers willhave a low tolerance for an incompletedashboards service.1425.On the other hand, it must also bedeliverable – taking into account thepractical constraints and circumstanceswithin the industry to ensure providershave a reasonable expectation of beingready to connect, regulators’ capacityto cope effectively with the increasedregulatory demands, as well as thecapacity of the digital architecture.26.In addition to these driving principlesof pace and deliverability, we have alsoconsidered other factors such as howto minimise competition impacts instaging, how to ensure opportunities totest, learn and improve are built in, andpotential impacts of the staging model onconsumers who may derive the greatestvalue from being reconnected withpensions and who may particularly benefitfrom seeing their pensions information(eg those closer to retirement).a. increase individual awareness andunderstanding of their pensioninformation and possibly theirestimated retirement incomeb. build a greater sense of individualcontrol and ownership of pensionsc. increase engagement, with morepeople taking advantage of theavailable advice or impartial guidanced. support the advice and guidanceprocess by removing the need tosearch pensions information duringany advice and guidance sessione. reconnect individuals with lost potsf. enable more informed user choices inthe decumulation phase by making iteasier to access the information onwhich to base these decisions13DWP Consultation, 2018142CV research for the Money Advice Service, 2017

Pensions dashboard: Staging Call for Input May 202127.We have also sought to consider theimpact of any staging proposals onconsumers in terms of equalitiesissues (ie any impacts on those withprotected characteristics): the approachshould not increase disparities inaccessing and understanding pensionsinformation – and if possible, it shouldreduce these. However, there is limitedevidence about the participation ofpeople with protected characteristicsin pensions and their engagement withpensions. We would welcome furtherevidence from stakeholders.28.This call for input provides a valuableopportunity for stakeholders to feed infurther evidence and insights to helpgovernment and the FCA come to a fullyinformed position on staging.29.In defining our recommendations below,we drew on a wide range of evidence,including data from TPR’s registry, FCAretirement stock income data, TPR andPDP research, and industry feedback toPDP’s call for input on data, publishedsummer 2020. We are particularlygrateful to the regulators for theirinsights and analysis, which have beencritical in developing these proposals.11Call for input30.Ahead of the government consultationon the legislation later this year andthe FCA’s corresponding consultation onrules, this paper sets out our proposalsfor implementing a staged approachto onboarding pension providers, forindustry feedback.31.The PDP occupies a unique space inbetween industry and government,which enables us to facilitate and feedin industry expertise and evidenceto government policy development.The intention of this call for input isaccordingly to share our thinking andrecommendations with industry andconsumer groups and seek feedbackon the proposals. This will enable usto gain vital evidence and insight fromstakeholders to help fill information gapsand inform the government and FCA’spolicy development.32.We are seeking responses to this call forinput by 9 July 2021. More detail on howto respond and a full list of the questionsis included at the end of this paper.

Pensions dashboard: Staging Call for Input May 202112PDP recommendations for stagingEarly staging33.34.35.36.In the interests of accelerating the paceof pensions coverage, we recommendthat early staging (ie bringing forwardsthe date by which providers areonboarded and ready to implement findand view functions) should be possibleand actively encouraged.Government regulations and FCArules will specify the dates by whichpension providers must connect tothe ecosystem and make savers’ dataavailable to them via dashboards.But early onboarding of pensionproviders into the ecosystem on avoluntary basis can proceed faster thanthis, and the PDP actively encouragesthis earlier participation, particularlyfrom the largest providers. Early stagingwould help us achieve a critical massof pensions findable sooner, which,in turn, may enable savers to haveaccess to their pensions information viadashboards sooner.This early staging will give pensionand data providers more control overtheir individual delivery timeline. It willalso maximise onboarding efficiencyby allowing administrators or ISPs toconnect multiple schemes at once inbulk, rather than having to repeat theprocess to connect each client on theirrespective staging date.37.This should also enable connectingparties to keep costs lower for theirclients, by reducing the effort requiredto connect schemes if clients can beconnected into the ecosystem in bulk.There is appetite in industry for this,and it will deliver a better experiencefor consumers.38.Therefore, we recommend there shouldbe a mechanism to allow pensionproviders to onboard in advance oftheir staging date. To help us managecapacity of schemes onboarding, earlystaging will be subject to our control. (Ifyou are a pension provider consideringonboarding early, we encourage you toget in touch with us.)Call for Input questionsQ9: Do you see any barriers to early staging?Q10: [Data providers] What is yourappetite for staging early? Are therethings PDP could do to encourage you toonboard earlier?

Pensions dashboard: Staging Call for Input May 202113Recommended scope for staging:prioritise FCA regulated providers ofpersonal pensions and occupationalschemes with 1,000 members39.The requirements in government regulations and FCA rules should focus, in the firstinstance, on FCA pension providers and occupational pension schemes that have at least1,000 members. We are referring to this as the first staging wave. This wave includes:SchemesNumber included in wave oneMaster trusts36 authorised schemes15Personal pension schemes124 authorised providers and groups16Other occupational pension schemes with1,000 membersc1,300 schemes1740.TPR data shows that pension scheme memberships are highly concentrated: the largest86 schemes (with over 100,000 memberships per scheme) represent only a fraction ofregulated pension schemes, yet account for 82% of memberships. We can include 99%of entitlements on dashboards by staging only schemes with 1,000 members.Although our recommendations do not only take size into account, this illustrates theconcentration of memberships within a relatively small number of providers. (We set outlater in the paper how this first wave should be split into defined cohorts and how eachcohort in the first wave meets the objectives of pace and deliverability.)15As listed on TPR’s website May 202116With uncrystallised pots. REP016 retirement stock income data and withdrawals 2019/20. Source: FCA regulatory returns, REP016[unpublished]17TPR registry data as at 1 April 2021

Pensions dashboard: Staging Call for Input May 2021Size band(memberships)TotalschemesProportionof schemesProportion ofactive and deferredentitlementsOver 1 1%2-1128,15981.4%0.1%Source: TPR registry data as at 1 April 2021 (which covers both occupational and personal/stakeholder pension schemes)18Figure 1: Cumulative proportion of schemes and memberships, by scheme size18The table is for schemes as registered with TPR, but it should be noted that FCA authorised providers of personal pensions (whomay operate multiple schemes), rather than schemes, will be the subjects of compulsion duties under FCA rules14

Pensions dashboard: Staging Call for Input May 202115100%90%80%70%60%50%40%30%20%10%0%Over 1 million10,000 - 99,999100,000 - 999,9991,000 - 4,9995,000 - 9,99912 - 99100 - 999Cumulative proportion of memberships2 - 11Cumulative proportion of schemesSource: TPR registry data as at 1 April 2021 (which covers both occupational and personal/stakeholder pension schemes)41.Staging FCA regulated providersand large occupational schemes firsttherefore helps meet the policy objectiveof maximising coverage of pensionsfindable as soon as possible.b. compared to smaller occupationalschemes, large occupationalschemes are more likely to betechnologically sophisticated:i. have digitised records42.Available evidence also suggests thatlarge occupational schemes should be ina better place to prepare for dashboardsand be able to comply:19a. large trust-based schemes aremore likely to engage frequentlywith administration at trustee boardmeetings, measure their data, identifyissues, and take action where dataissues are identified19ii. offer online access to their members(this is particularly pronounced forDC schemes)43.Similarly, existing disclosure requirementson FCA regulated providers and mastertrusts and other DC occupational pensionsused for Automatic Enrolment mean theseare likely to be ready for dashboards sooner.TPR DC survey 2020; TPR DB survey 2020 [forthcoming]; TPR registry data 2021

Pensions dashboard: Staging Call for Input May 202144.Focussing on a relatively small numberof providers, who account for the bulk ofmembers initially also enables PDP andTPR to ramp up their functions, and thecommercial ISP market to emerge, whichwill be critical for smaller schemes to beable to comply.They are already making the changes,alongside colleagues in HM Revenue &Customs, to ensure that the infrastructurerequired to provide State Pensioninformation will be in place ahead of thefirst publicly available dashboard.48.45.46.Government intends to consult on theregulations by the end of 2021 and lay theregulations before parliament in

Executive summary Pensions dashboards will allow consumers to see their pensions in one secure place online. Legislation and rules will introduce a legal requirement on pension providers to connect into the pensions dashboards ecosystem and make pensions