PDP Pensions Dashboards: Staging call for input consultation - Which? response

Which? broadly supports the Pensions Dashboards Programme’s proposed approach to the staging of pension schemes, but earlier take-up should be encouraged.

Which? supports the Pensions Dashboards Programme’s proposal for requirements for pensions schemes to provide data to pensions dashboards to be predominantly based on the size of scheme. As we set out in our report on the pensions dashboard in 2018, smaller schemes especially may need longer than others to provide data to pensions dashboards. The Pensions Dashboards Programmes’ proposed approach is a proportionate way to ensure pension schemes are ready to provide reliable and accurate data to pensions dashboards while covering as many pension memberships as possible at the earliest date. 

Within the proposed first wave of large schemes, we agree that defined-contribution schemes are the more immediate priority for consumers. Defined-contribution schemes are also more likely to be ready to connect to dashboards, given that they are already required to provide annual benefit statements that include the key data requirements proposed for dashboards and many of the large schemes have online customer-facing services. Nonetheless, defined-benefit schemes are also important given the number and value of deferred pots among people approaching retirement, and these schemes should come on at the earliest opportunity. 

Furthermore, some schemes can and should provide data to dashboards earlier than the proposed deadlines. We therefore agree that this should be enabled and encouraged. This will help to speed up the testing of the system.