PDP Design Standards call for input - Which? response

Which? welcomes the Pensions Dashboards Programme’s (PDP) call for input on design standards. Dashboards will play an integral role in driving individuals’ engagement with their pensions and equipping users with the right information to make informed decisions about their retirement savings. Hence, the way in which pension information, pensions value data and messaging is presented on dashboards will be critical to furthering individuals’ understanding of their pensions and in ensuring strong consumer protections for all users of Qualifying Pensions Dashboards Services (QPDS).

• We support the following proposals on design standards:
  • For the PDP to adopt a principles-based approach to ensure that QPDS explain the core functions and, in particular, the service limitations of dashboards to all users. As missing pension information and value data on dashboards could be frustrating and disappointing for some users, dashboard providers should be required to provide a clear explanation as to why there are omissions, if any, and when the user can expect to view this information at a later point.
  • For the PDP to require QPDS to provide an explanation of the regulatory environment to users, and make clear that all QPDS are regulated by the Financial Conduct Authority (FCA). We also support the PDP working with the FCA to ensure that users are aware of the consumer protections they have whilst inside the dashboard ecosystem. This is important if the FCA decides to allow the ability for individuals to export their pensions data outside the ecosystem.
  • For the PDP to mandate the key underlying information and value data that must be included in displays of view requests, explanations and display warnings on QPDS.

• We support the PDP’s approach to striking an appropriate balance between flexibility and prescription in the design standards. For example, allowing QPDS to decide what format value data will take on dashboards, how information is presented or summarised, and what language to deploy to best communicate information to its users. Whilst we recognise the importance of mandating some of the key underlying information that should be displayed on dashboards, the standards must also give QPDS flexibility in the way they present information to promote greater innovation and engage savers with varying needs and levels of understanding. Moreover, the PDP could be more outcomes-based in its approach to display warnings to enable QPDS to be more innovative in how they communicate this information to their users.
• We strongly agree with the PDP’s approach to favour the user’s needs over those of the QPDS in any instances of conflict. As the aim of pensions dashboards is to support individuals in planning for retirement, it is crucial that consumer outcomes are central to design standards and take precedence over the interests of dashboard providers. Furthermore, the PDP must give more consideration to vulnerable consumers and accessibility standards in its proposals.
• The PDP should implement design standards as soon as possible following testing. As FCA rules for dashboard providers are due to be finalised by the end of 2022, this should give the PDP sufficient time to ensure that design standards complement FCA rules for QPDS. Moreover, the design standards should evolve overtime to better meet the needs of consumers and further individuals’ engagement with their pensions.