enquiries@dthomas.co.uk • +44 (0) 23 9282 2254
25 Apr 2024
First seen on Professional AdviserRecently, the DWP released its guidance on its approach to a staged timeline for different types of pension schemes to be connected to the Pensions Dashboard.
Firstly, schemes which haven’t already done so, need to have a digital interface in place to connect your scheme to pensions dashboards.
The following steps need to be completed before you are ready to connect.
Your digital interface could be provided by either using an interface built by your scheme’s third-party administrator or software / IT supplier, building your own interface if the scheme is administered in-house, or by using an interface provided by a third-party integrated service provider (ISP).
The digital interface you choose must meet the Pensions Dashboard Programme (PDP) standards. These standards include 24/7 availability, rapid response times, the ability to cope with high volumes of find and view requests and the interface must be independently verified by a third-party security test.
If you are building your own interface connecting to the digital architecture is a significant undertaking which will require specialist technical expertise to build and maintain systems that can meet the required standards. This will take time and therefore trustees or managers and pension scheme providers intending to build a direct connection should engage with PDP as soon as possible, if they have not already done so.
A significant proportion of schemes will opt to connect via a third-party organisation, either their existing administration system software supplier or an by using ISP who will undertake the technical complexities of dashboard connection and adherence to the PDP standards, greatly reducing the burden on scheme trustees. It is recommended that trustees or managers and pension scheme providers intending to connect via a third party should engage with the relevant organisation well in advance of their ‘connect by’ date.
You should carefully consider all these aspects before deciding on the best solution for you. Whichever approach you take, you remain accountable for ensuring your scheme is connected to dashboards on time and that it remains compliant. You should ensure robust processes are in place for the selection, appointment, management and replacement of any suppliers.
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The Pensions Dashboards Programme data standards set out the type, length and format requirements for key data (for example, how dates should be formatted and whether fields are compulsory or conditional). You will need to ensure that your data is prepared in the correct format to connect smoothly. You will also need to prepare your data for matching and up-to-date value data of members’ pensions.
In order to connect your scheme to the digital architecture, MaPS will need to be satisfied you have met its standards.
If you are connecting the scheme directly, you will need to provide evidence that you meet these standards, through conformance and compliance testing, and an IT health check. This can be a time-consuming process, so ensure that you register your interest with the PDP as soon as possible.
If you are connecting your scheme through a third party, such as Dunstan Thomas, then we will go through the testing and certification with PDP directly. This means that you will not need to go through dashboard connection testing directly, and can apply your focus to preparing your data for connection.
Whichever route to connection you choose, you will also need to ensure that your scheme is registered with MaPS’ Governance Register (An ISP will do this for you). This will ensure the digital architecture is kept safe by allowing only regulated schemes to connect and that the required security and performance standards are met. You must co-operate with requests made by MaPS about your connection and let them know if you face any barriers or connection issues.
When connection is complete, you should be able to:
The Pensions Dashboards Programme have done a good job at keeping the collaboration and engagement going with pensions dashboard volunteer participants through the reset, but there are certainly challenges ahead in getting standards finalised, built and tested for all connectors ahead of the connection timescales. Chief amongst these are the data standards which are due to be rubber stamped by the Secretary of State for Work & Pensions. We will soon be releasing a second article, covering these standards.
However, you also need to bear in mind a raft of other PDP standards:
Technical (and API) standards. This concerns the requirements for how pension providers, schemes and dashboards interface with the central digital architecture and with each other, including connectivity mechanisms, protocols for authorising the sharing of information, and the generation and registration of pension identifiers.
Design standards. This covers the PDP requirements for presentation of the pensions data on dashboards and design of the dashboards.
Reporting standards. i.e. the data required from pension providers, schemes and dashboards to monitor the health of the pensions dashboards ecosystem, compliance and performance.
Security standards. This refers to the technical, procedural and physical, standards for pension providers, schemes and dashboards to ensure security of the ecosystem (part of the code of connection).
Service standards. i.e. the minimum service requirements and required behaviour of pension providers, schemes and dashboards including; service availability and response times, software compliance, software interoperability, dealing with failed requests, connection state changes (including planned interruption to information technology systems) and when to notify PDP of personnel changes (part of the ‘code of connection’).
Operational standards/ i.e. the operational processes pension providers, schemes and dashboards must follow to connect to the ecosystem and to maintain connection, including onboarding procedures, dispute management and escalation, service level failure protocols.
There is a real risk that if one or two cohorts miss their staging date and this could push the next group of staging dates backwards. For example, if there are delays onboarding of parliamentary pensions schemes of all sizes which mean they are not ready to connect to MaPS by their 31st October 2025 staging deadline, this could mean that medium sized schemes without money purchase benefits and remaining hybrid schemes (both with 1,000 to 1,499 members) are pushed back beyond their 30th November 2025 as the dashboard testing infrastructure becomes overstretched.
This is why it is vital for all schemes to have regard for the guidance and agree their connection approach early to avoid bottlenecks for the programme.
These are very complex interfaces. Once the data fields have been fully populated and validated, testing of the process of finding and viewing individual’s pensions data will need to begin in earnest. It is possible that glitches in data retrieval and data display will occur. We sometimes see these when different browsers are used to access portals for example.
The testing period for meeting viewing requirements will prove challenging, especially for providers that are connecting directly to dashboards. This work may be scheduled too late simply because providers spend too long updating, enriching and validating the data of members and don’t leave enough resources and time to get the ‘view’ testing completed using multiple different devices and browsers.
Despite the hard focus by the PDP, DWP and the regulators on getting scheme operators and providers to get their members’ data accurate, up to date and in fields as directed by the PDP Data Standards, we think that some schemes will not be ready due to very specific data formatting rules not being completed. Others will think they have good data but will not have run enough checks to make sure it is all accurate. We have seen examples of some really poor data over the years.
For those worried that their specific staging deadline looks tight and the challenges appear to be piling up, it is logical to look for a trusted ISP which is steeped in all the above challenges. The challenges are broadly associated with updating and validating their members’ data, completing the complex digital interfaces and being ready to connect to the dashboard infrastructure in order to run find and view requests concurrently to the expected volumes (see my second article out next month on testing for scalability).
We are excited by DWP’s recent announcement and feel confident we have the right solution in place to handle these challenges now that staging deadlines have been set for the second, and hopefully last, time.
Paul Muir
Chief Product Officer at Dunstan Thomas
023 9282 2254
enquiries@dthomas.co.uk