DWP publishes mammoth draft consultation on dashboard regulations

Emily Forrest, partner, comments on the draft consultation on the dashboard regulations published by the DWP:

“Dashboards are coming. The Rubicon long-crossed, we have known this for several years. But if anyone was in any doubt about the scale and complexity of bringing the dashboards project into operation, the mammoth DWP Consultation published earlier today on the draft Pensions Dashboards Regulations 2022 makes it abundantly clear.

The entire pensions industry now has just six weeks to get to grips with a huge swathe of issues. These range from when and how to measure the size of a scheme (not as obvious as it sounds, given that the timing of required compliance hinges on this) to whether it will be appropriate to provide figures to the dashboard using a simplified methodology which diverges from the one used to calculate benefits under a scheme’s rules.

With over forty such questions to consider, it will be important for us all to test the DWP’s proposals against the underlying concerns we are most keen to see addressed so that unintended consequences are avoided. From the point of view of pension schemes and providers, hot-spots will include: clarity about data matching processes; GDPR compliance; requirements about recency of data; and questions about who will be liable for data that is wrong or not provided. Like so many others in the industry, we have our dashboards hopes and fears. So, time for the careful reading to commence…”