DWP’s Pensions Dashboards: further consultation - Which? response
Summary
Which? welcomes DWP’s further consultation on pensions dashboards. We welcome the Government’s clarification and further consideration on both a Dashboards Available Point (DAP) for consumers and the disclosure of information between the Money and Pensions Service (MaPS) and The Pensions Regulator (TPR) within draft pensions dashboards regulations.
We support the Government’s proposal to include a provision within regulations outlining that the launch date for dashboard services will be specified in a notice issued by the Secretary of State. This would focus the minds of all participants on the imminent launch of dashboard services and give pension schemes, dashboard providers and technology platforms a clear deadline in the final stages before launch to make all final preparations by.
We support DWP’s proposed 90 day notice period between the announcement by the Secretary of State and the DAP. A three month notice period should give industry sufficient time in the run up to launch to prepare for any delivery challenges that may arise when matching users with their pension information. Moreover, it will be a crucial time for the Government, MaPS and the wider pensions industry to build individuals’ engagement with pensions dashboards and promote the use of dashboard services in the longer term.
In addition to a formal 90 day notice period, Which? continues to believe that the Government should publicly outline its expectations for when dashboards should be launched to consumers at its earliest opportunity. Based on current timings and assuming both the successful onboarding of schemes and successful user testing, Which? estimates that April 2024 could be a feasible date for pensions dashboards to be launched to consumers.
We support DWP’s additional provision to establish a clear power in regulations to expressly enable MaPS to disclose information to TPR in relation to dashboards. The sharing of relevant information about pension schemes between bodies will help to ensure that MaPS, TPR and the Financial Conduct Authority (FCA) are able to effectively carry out their responsibilities and support the running of the dashboards ecosystem. It is vital that relevant pension data is securely shared between these bodies.
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