The recent announcement that there will be a delay in the Pensions Dashboards staging dates is welcome but comes with a risk.  It’s absolutely not a chance to relax on all the work that schemes, providers, administrators and third parties need to do.  The pedal must stay to the metal. 

It’s about data availability as well as quality

Whilst the ability to connect to the API layers and send messages back and forth has been delayed, and will likely need a tweak to the standards, I expect no change in the rest of the work – namely, making the data available digitally on demand.  This has always been the main job for pensions firms and schemes. 

I know many people hone in on the data quality, which is of course vital, but there is other work that is also vital.  There is no use in having perfect data in a system you cannot access 24/7 and reply in 60 seconds.  There are huge swathes of pensions data that currently is housed on systems without this capability. 

In the background the large firms having been working to resolve this issue, by making the data available from systems that can be up 24/7.  Often the solution is to put the data from the back end systems into a large database or data lake.  This really suits firms who have many back end systems, often with legacy and heritage books acquired through acquisition.  Some are building these in house, others are using the ISP firms to do it for them.  Smaller schemes and firms with small books are more likely to just give an extract of the data to the ISP.

But the real challenge is in ensuring  that the data is kept up to date.  People after all have a habit of moving house or changing their name, and even transferring their pensions.  So you need systems and processes in place to update the date in the data lake or with the ISP regularly.  

Data quality

Yeah, fix that too.  Otherwise firms will have a LOT of possible matches.

Don’t assume the delay is as long as you think

Everybody and their dog has their opinion on how long the delay will be.  I’m a 9 month chap myself.  But what if it’s only 3 months or 6 and you assumed it would be at least a year and gave the project team away? 

But more of an issue I think is that whilst the first staging date will go back a certain period of time, there is no guarantee that all dates will move back the same amount.  The logic within Government may well be “they have had years to get ready for mid 2024 and the system will be ready by then so why do they need another 9 months?” 

There is a real risk some organisations put back their delivery based on assumptions that may be wrong.  This is a particular worry as it may take several months for the DWP to decide the new staging dates and it’s conceivable that firms will only be given a few months’ warning. 

There’s no excuse now

It’s possible that every firm that needed to would have got 100% of their policies ready for the August ‘23 deadline.  Far more likely is that firms will at some point have gone to the FCA / TPR  explaining why this small book or that might not quite be ready for August.  “Please sir, can we have an extension for a year?” 

Well I imagine the FCA will not be minded to push that extension back another 9 months.  The thinking is more likely to be along the lines of, “Well as the whole thing is going back you can do that other book as well, can’t you?” 

In general I also think this delay, which the industry asked for, will harden the regulators’ minds on the eventual compliance when the staging dates do hit. 

I would say they are right.  Dashboard has been coming for 7 years, there really should be no excuses not to be ready.

Need help?   

And finally a small pitch for myself.  If you are still concerned that you may need help making sure you meet your Pensions Dashboard obligations, please get in touch.