Pensions Dashboards: guidance on deferred connection

The Department of Work and Pensions (DWP) has published an updated version of its Pensions Dashboards: guidance on deferred connection. The guide relates to the new upcoming requirements of pension fund schemes to connect to the pension dashboard „network“ and a possible deferral of such deadline for individual schemes with the approval of the DWP. Specifically, the guidance outlines
– the steps pension scheme managers or trustees must take to apply for a deferral of the obligation;
– the form that must be used for such applications;
– the data and documents that shall be submitted alongside the application;
– possible grounds for a deferral;
– the factors the DWP will consider when evaluating an application; and
– the final decision and the (non-existing) possibility to have the decision reviewed.
The update follows the recent publication of the Pensions Dashboards (Amendment) Regulations 2023 which modified the Pensions Dashboards Regulations 2022 (SI 2022/1220) primarily to adjust the regulations due to delays in the implementation of the infrastructure for the pension dashboard „network“. Specifically, the new regulations specify a new single connection deadline (connectivity date) by which all relevant pension schemes must be connected to the dashboard „network“ which will be October 31, 2026. Before this delay, there was a phased-in approach (staging profile) which required the largest schemes based on the number of members to connect to the network first with the smallest following last.
The guidance and enclosed application form have now been updated to reflect this new deadline.