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When your scheme needs to connect with dashboards

The Department for Work and Pensions (DWP) has recently laid the Pensions Dashboards (Amendment) Regulations 2023.

The DWP and the Money and Pension Service (MaPS) will publish guidance setting out a staging timeline for schemes, and we will update our guidance accordingly. The staging timeline will indicate when schemes (by size and type) are scheduled to connect.

You must have regard to the guidance put out by the DWP and MaPS.

All schemes with 100 or more relevant members at the scheme year end between 1 April 2023 and 31 March 2024 must be connected by 31 October 2026.

If you did not have 100 or more relevant members at scheme year end 2023 to 2024, but you do on and after 1 April 2024, you will be required to connect by the later of:

  • six months after the end of the scheme year in which that threshold was reached
  • 31 Oct 2026

You have to connect the whole scheme at the same time. If your scheme has multiple sections or your members have additional voluntary contributions (AVCs) in the scheme, these will all need to be connected at the same time. You will need to work with your administrators and AVC providers to ensure your whole scheme is connected.

Deferring your deadline

You may be able to apply to the DWP for a one-off deferral to the 31 October 2026 connection deadline. The only grounds for deferral are if you have either:

  • embarked on a programme to transfer the data held by the pension scheme to a new administrator
  • entered into a contract containing an obligation to retender the administration of the scheme and the timetable for this is reasonable and conflicts with the staging deadline for the scheme

You will need to evidence this and demonstrate that it will be disproportionately burdensome or put the personal data of members at risk to connect by the deadline. The maximum deferral you can receive is 12 months.

You will need to do this within 12 months of the amending regulations coming into force and as early as possible to ensure your application can be considered in time.

The DWP has published deferral guidance to help trustees and managers understand the application process for deferral.

Schemes in Pension Protection Fund (PPF) assessment

Schemes that enter PPF assessment before the connection deadline are not required to connect by the deadline. If the scheme exits PPF assessment but does not enter the PPF, it will need to connect by the later of:

  • the deadline
  • six months from the end of the assessment period

The above only applies where the whole scheme is in PPF assessment. If only a section of your scheme is in assessment, your connection duties still apply.

Voluntary connection

Schemes with 99 or fewer relevant members are not in scope of the regulations but they may be included in future legislation. They can apply to connect on a voluntary basis.

If you choose to connect voluntarily, you must be able to find members and send them data as soon as you are connected and meet the requirements that are applicable to schemes in scope. You will need to apply to the MaPS and follow their guidance. Talk to your administrator or provider if you would like to connect voluntarily.

1. Overview
Connecting to pensions dashboards