Master trusts with 20,000 or more relevant members currently have until 31 August 2023 to connect to pensions dashboards. With just under a year until this first cohort are required to connect, now is a good time for trustees to reflect on where they are with pensions dashboards and, most importantly, what they still need to do.

Trustees should consider the five questions below as a starting point for becoming “dashboard ready”.

When do trustees need to connect?

Although only the largest master trusts need to connect to dashboards by 31 August 2023, deadlines for other schemes quickly follow this.  

As such the Pensions Regulator has advised that trustees should ensure they understand their connection deadline and what is required from them.

The connection timeframes for different types of schemes are as follows:

• Master trusts: Deadlines from 31 August 2023 onwards
• DC Schemes used for automatic enrolment: Deadlines from 30 September 2023 onwards
• DB schemes, all other DC schemes and all hybrid schemes (including hybrid master trusts): Deadlines from 30 November 2023 onwards

The specific connection deadlines for different types of schemes vary depending on size, with the smallest schemes having until 31 October 2025 to connect.

Is the subject of pensions dashboards on trustees’ agendas?

The subject of pensions dashboards should be given regular time on the agenda at trustee meetings. This will help trustees focus on the steps that trustees will need to take to meet their duties. If a scheme has sub-committees, it is a good idea to decide early on who will be responsible for over-seeing the day-to-day preparation for pensions dashboards.

Boards will need to consider all of the questions discussed here, as well as other specific issues such as:

• whether trustees have the necessary external support to meet their dashboard duties;
• whether trustees want to connect early;
• whether trustees have the resources and processes set up to deal with member queries on dashboards; and
• whether trustees have set aside a sufficient budget for pensions dashboards work.

Have trustees discussed pensions dashboards with relevant parties?

As well as discussing dashboards internally, trustees should ensure that they are discussing what they will need to do with relevant parties. For example, trustees should discuss pensions dashboards with their administrator, software provider, actuary, legal adviser, employer and any AVC providers. 

How will trustees connect to pensions dashboards?

Speaking to relevant parties will hopefully help trustees understand the different ways of connecting to pensions dashboards and which approach similar schemes are taking. 

Schemes’ digital interfaces could be provided by:

• using an interface built by a scheme’s third-party administrator or software/IT supplier;
• building their own interface if the scheme is administered in house; or
• using an interface provided by a third-party integrated service provider (ISP).  

If trustees are considering building their own interface, this will be a significant undertaking that will typically require specialist resource and experience. We therefore anticipate that this will be of limited applicability. 

If using an interface provided by a third-party integrated service provider, trustees need to enter into agreements covering these services and ensure members’ data is adequately protected. 

Regardless of the approach trustees take, they will remain accountable for ensuring their scheme is connected to dashboards on time and that it remains compliant. 

Is the data “dashboard ready”?

Trustees should start assessing whether their dashboard-required data is:

• accurate;
• calculated in line with requirements (including forthcoming changes to AS TM1);
• sufficiently recent; and
• digitally accessible. 

This will allow trustees to put in place plans to improve the data in these ways if required. 

On the horizon

We are still awaiting the finalised Pensions Dashboards Regulations, as well as finalised guidance from the Pensions Regulator and various standards, specifications and technical requirements. Until these are published, there will be uncertainty about what the final requirements will look like. 

However, due to the significant work involved in becoming “dashboard ready”, trustees cannot wait until regulations are finalised before starting to prepare.