In the next few days we expect to start to hear publicly how the Pensions Dashboard Program has progressed since the reset was announced in March.  In advance of that re-engagement, here are the five things I think we need to know.

Actually just before I start, a wee caveat.   I don’t expect the answers to these questions right away, although it would be nice.   But we really do need to make sure that we have the answers soon, or at least know when we are going to get them. 

One – A realistic timeline

The biggest need really is a timeline.  This allows the hundreds of firms that need to do the work to deliver pensions data to the system to plan their work.  Starting with the first guidance date for staging and working backwards to the first date for connection. 

The reason we need this ASAP is that getting the projects back up and running in firms / schemes is not a small deal.  The reality is that most firms have parked their projects and the people working on them are doing other things.  Getting the business analysts, programmers and project managers back will take time.  Plus the budgets need to be raised again.  

The other point is that it needs to be realistic and achievable.  By the end of last year it was becoming clear that the original plan was not going to be met.   This means that frankly there is a lot of cynicism around the project.   The plan needs to be credible this time and then it must be kept to.

Two – Final Data Standards (or at least updates)

Quite a technical one this.  The data standards have been sitting at the same version for a long time.  It is understood that there will be updates but these have not appeared.  This means that teams working to get ready have not been able to progress, as they know they will have to do rework.

I get that we may not be able to go to a final version straight away but clarity on which changes are next is important.   Without this, no IT work can really be undertaken.

Three – Finalise the FCA rules on hosting a Dashboard

The FCA consulted on the rules for hosting a Dashboard at the start of the year.  I know because it occupied a lot of time in January and February!  And since the responses went in we have heard nothing.  My understanding is that the treasury need to officially put in place the mechanism to make these full regulations.  So what’s keeping them from doing so?   The sooner we get the final rules, the more time there is for the numerous firms that are interested in hosting a Dashboard to get going.

This is actually quite an issue.  Several organisations are in a position that they cannot progress to the next steps in planning.  In particular, I am concerned that some firms that were going to enter the market as third parties offering of the shelf Dashboards are losing patience.   If we want there to be a variety of quality Dashboards for customers we need this market to flourish and I worry that the delays will lead to a lack of competition.

Also, until the rules are final, the process cannot start to get the permissions required  to run a proper user testing phase.  Which brings me to….

Four – A plan for a beta phase with real customers

The cardinal rule of web development is to test with real customers.  Oh, and it’s a basic tenet of the consumer duty rules as well. 

So prior to the full-bore launch to the whole of the UK we should test the Dashboard with real people using the real system.   And I don’t mean a couple of dozen pensions nerds.   I mean thousands of people across multiple schemes, on multiple Dashboards.

The first reason to do this is to test people’s attitudes and use of the Dashboard.  Richard Smith has published excellent research showing that the moment people see their own real pensions information you get a better idea of what their reactions will be.

The other reason to do so is that we really need to test matching rules with real people.  All the work on data quality now is important, but it’s not a replacement for testing with live data on real people. I fully expect that we will have to tweak matching rules to get better results.  Probably best to do that before we go live with millions of people!

Five – Pick an ID solution

The entire Dashboard process relies on there being a reliable technical way to identify the customer and their details to a good standard.  Unless I can prove that I am Ian Macintyre,  this one, not the dude that does interesting things with teapots at Ian McIntyre, then nobody can give me the details on my pensions.  Which is the whole point.  It’s made harder in the UK as we don’t have a national ID that can be used.

The thing is, we have not actually agreed on how to do this yet.  Digidentity were appointed to be the service to use in testing.  But their contract runs out soon. 

We don’t even know if it will be the government ID service GOV.UK One Login or a commercial service.   This is pretty important as if it’s the GOV.UK One Login service my understanding is that it cannot be reused by firms for wider pensions use.  If it’s a commercial service, how will it be paid for?    

The ID solution seems like quite a technical thing but I have always been worried that the lack of a usable system is the biggest risk to the success of Pensions Dashboards.  

In summary, the Pensions Dashboard Program has a lot of things it needs to clear up, and quickly. Otherwise we may find ourselves wondering in a year’s time why there are calls for another delay – or even to can the whole thing.  I really think this is the last chance to get this done properly.