Guidance

Pensions dashboards: guidance on connection: the staged timetable

Published 25 March 2024

1. Background

1.1 About pensions dashboards

Pensions dashboards will allow individuals to see their pensions information, including their State Pension, for free in one place online at a time of their choosing. Pensions dashboards will also reunite savers with lost or forgotten pensions. The ability to access information easily alongside an increase in individuals’ awareness and understanding of their pension information could also support people with better planning for their retirement.

2. Purpose of this guidance

2.1 Relevant legislation and rules

Part 4 of the Pension Schemes Act 2021 inserted sections 238D, 238E, 238G of the Pensions Act 2004 to legislate for the connection of occupational pension schemes to the pensions dashboards ecosystem. Sections 137FAA-137FAC of the Financial Services and Markets Act 2000 as inserted by Section 121 of the Pension Schemes Act 2021 placed obligations on the Financial Conduct Authority (FCA) to make corresponding general Rules imposing requirements on providers of personal and stakeholder pension schemes.

The Pensions Dashboards Regulations 2022 (the ‘2022 Regulations’) introduced requirements for occupational pension schemes to connect to the pensions dashboards ecosystem and respond to requests for pensions information. In November 2022, the FCA introduced corresponding requirements for providers of personal and stakeholder pension schemes (COBS 19.11 of the FCA Handbook).

The Pensions Dashboards Regulations 2022 as amended by the Pensions Dashboards (Amendment) Regulations 2023 introduced a single “connection deadline” of 31 October 2026 for relevant occupational pension schemes to connect to the pensions dashboards ecosystem. References to the 2022 Regulations in this guidance are therefore in reference to the amended version of those Regulations.  The FCA made a corresponding amendment to its Handbook Rules.

2.2 About this guidance

All schemes and providers in scope are legally required to be connected to the pensions dashboards ecosystem and be ready to respond to requests for pensions information by 31 October 2026 at the latest.

This guidance sets out a staged timetable for occupational pension schemes and personal and stakeholder pension providers to be connected to the pensions dashboards ecosystem and be in a position to process ‘Find’ and ‘View’ requests.

Guidance issued by the Pensions Dashboards Programme (PDP) will provide further detail on the process of connecting to the pensions dashboards ecosystem including, but not limited to, when to contact the PDP and the onboarding process. This guidance should also be read in conjunction with the PDP standards, including the Code of Connection.  PDP will produce connection and testing materials to support the pensions industry in their connection journeys. Furthermore, The Pensions Regulator (TPR) has issued guidance to support schemes with connecting and supplying data to the pensions dashboards ecosystem. Their guidance includes a checklist^{[footnote 1]} which schemes can use in preparing to meet the requirements for connecting to the pensions dashboards ecosystem.

The Department for Work and Pensions has, in collaboration with key partners (the PDP, the FCA, and TPR), consulted on and engaged extensively with industry on the principles underpinning a staged approach to connection. This engagement included the PDP’s 2021 Call for Input on Staging and the Government’s consultations on the 2022 Regulations. This was supplemented by additional engagement with a wide range of industry representatives in Autumn 2023.

As informed by the evidence collected during this engagement activity, the connection timetable in this guidance prioritises schemes and providers with the greatest number of memberships. This approach, if followed by industry, will ensure a sufficiently high level of pensions memberships will be available to ‘Find’ and ‘View’ on pensions dashboards as early as possible, in turn enabling the launch of pensions dashboards for use by the public at the earliest possible point.

Retaining the broad framework of a phased approach to connection will be important in managing the flow of connections to the pensions dashboards ecosystem. Working with industry, PDP expects to facilitate connection in line with the “connect by” dates in guidance, ahead of the connection deadline in legislation. Trustees or managers and pension scheme providers connecting too close to the connection deadline of 31 October 2026 could place undue strain on all parties involved in facilitating connection, including PDP, administrators, and Integrated Service Providers. Where trustees or managers and pension scheme providers connect later than their “connect by” date in guidance, they do so at greater risk of not being connected by the connection deadline in legislation.

Whilst the timetable is not mandatory, given that it is being published to ease the connection journey, DWP would encourage trustees or managers and pension scheme providers to follow the dates in this guidance unless there are exceptional circumstances which prevent them from doing so.

2.3 Who is this guidance for?

This guidance is applicable to trustees or managers of relevant occupational pension schemes^{[footnote 2]}, including trustees of occupational pension schemes which voluntarily bring themselves into scope of the 2022 Regulations (as set out in regulation 16), and providers of personal and stakeholder pensions. For the remainder of the guidance the term ‘trustees or managers’ will be used to refer to trustees or scheme managers of relevant occupational pension schemes, and ‘pension scheme providers’ will be used to refer to providers of personal and stakeholder pension schemes.

Parties that intend to support schemes with their connection to the pensions dashboards ecosystem (such as advisers, administrators, and Integrated Service Providers) may also benefit from familiarising themselves with the guidance. Potential providers of Qualifying Pensions Dashboard Services (QPDS) may also find this guidance of interest.

This guidance is applicable to occupational pension schemes in England, Wales, and Scotland which are in scope of the 2022 Regulations. This guidance applies across the United Kingdom for pension scheme providers subject to FCA Rules. The Department for Work and Pensions is working closely with the Department for Communities which has made corresponding regulations for pension schemes based in Northern Ireland.

2.4 The legal status of this guidance

The Secretary of State at the Department for Work and Pensions has issued this guidance. Trustees or managers and pension scheme providers must have regard to the guidance in order to comply with the requirement in regulation 15(2)(d) of the 2022 Regulations and COBS 19.11.8R of the FCA’s Handbook. Not having regard to the guidance would be a breach of these requirements. This means that trustees or managers and pension scheme providers must take the guidance into account when preparing to connect to the pensions dashboards ecosystem.

2.5 Regard to the guidance

The 2022 Regulations specify that trustees or managers must have regard to guidance on connection issued from time to time by the Secretary of State, the Money and Pensions Service and The Pensions Regulator, either separately or by at least two of them jointly. Similarly, the FCA’s corresponding Handbook Rules require firms to have regard to the guidance with due skill, care, and diligence.

It is a legal requirement for trustees or managers and pension scheme providers to have regard to this guidance as part of meeting their obligations and not doing so would be a breach of this requirement. As such, trustees or managers and pension scheme providers must consider it when making decisions or taking actions in relation to preparing to connect to dashboards.

Trustees or managers and pension scheme providers will need to be able to demonstrate, upon request, how they have had regard to this guidance. This means, but is not limited to:

• Not making final decisions about connecting before engaging with this guidance.
• Being able to demonstrate that adequate governance and processes for making such decisions are in place. The reasoning for decisions should be clearly considered and documented, as well as how relevant risks are identified, evaluated, and managed.
• Making sure that access is available to all relevant information before making decisions and acting upon them. Keep clear and accurate audit trails to demonstrate the decisions made, the reasons for them and the actions taken.

If trustees or managers and pension scheme providers are unable to demonstrate how they have had regard to the guidance, this may result in enforcement action by the relevant regulator.

2.6 The connection journey

There will be two ways that trustees or managers and pension scheme providers may opt to connect to the pensions dashboards ecosystem –

• using an in-house technical solution by building their own direct connection; or
• buying the services of an Integrated Service Provider (ISP) or third-party administrator and connecting through them.

The Pensions Dashboards Programme (PDP) expects to facilitate connection in two stages. The first stage involves connection of any schemes or providers which will build a direct connection to the pensions dashboards ecosystem. The PDP expects to begin this first stage ahead of widescale connection commencing as per the staged timetable.  

Building an interface that will connect directly to the pensions dashboards ecosystem is a significant undertaking which will require specialist technical expertise to build and maintain systems that can meet the PDP standards and deal with high volumes of ‘Find’ and ‘View’ requests. Extensive testing will be required to evidence meeting the standards, including an independent third-party security test. 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. 

The second stage will involve connection of schemes and providers which will use a third-party organisation to facilitate connection. The “connect by’’ dates which are set out in this guidance are premised on the expectation that trustees or managers and pension scheme providers which have not already approached PDP to build a direct connection will be doing so using the services of a third-party organisation which has already completed its own direct connection to the pensions dashboards ecosystem. 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.

Commencing connection testing with the PDP in a timely manner will increase the likelihood of trustees or managers and pension scheme providers being in a position to process ‘Find’ and ‘View’ requests by their assigned date. Once connected, all requirements apply - including the requirement to remain connected. Importantly, and irrespective of whether they are connecting directly or via a third-party organisation, all trustees or managers and pension scheme providers should be ready at the time of connection to receive ‘Find’ requests, undertake matching, and return ‘View’ data, pursuant to the requirements in the 2022 Regulations and FCA Rules.

 3. The staged timetable for connection

To note: “number of relevant members at reference date” should be calculated as:

• for trustees or managers of occupational pension schemes subject to the 2022 Regulations: number of relevant members per scheme (active members, deferred members, and pension credit members) at the scheme year end date in the period between 1 April 2023 and 31 March 2024.
• for pension scheme providers subject to FCA Rules: the number of pots in accumulation across all the relevant pension schemes the provider operates (personal and stakeholder pensions, retirement annuity contracts, pension buy-out contracts and Freestanding AVCs) at the scheme year end date in the period between 1 April 2023 and 31 March 2024.

Part 1: large schemes and providers

Cohort	Scheme type	Number of relevant members at reference date	Connect by
1(a)	master trust schemes that provide money purchase benefits only	20,000 or more	30 April 2025
1(a)	FCA-regulated operators of a personal pension scheme, stakeholder pension scheme, a retirement annuity contract, a pension buy-out contract including a ‘section 32’ buy-out policy[footnote 3] or an FSAVC	5,000 or more	30 April 2025
1(b)	money purchase schemes used for automatic enrolment	5,000 or more	31 May 2025
1(b)	master trust schemes that provide money purchase benefits only	5,000-19,999	31 May 2025
1(b)	any remaining money purchase schemes	20,000 or more	31 May 2025
1(b)	schemes without money purchase benefits, other than public service pension schemes or parliamentary pension schemes	20,000 or more	31 May 2025
1(b)	hybrid schemes	20,000 or more	31 May 2025
1(c)	master trust schemes that provide money purchase benefits only	1,000-4,999	30 June 2025
1(c)	money purchase schemes used for automatic enrolment	1,000-4,999	30 June 2025
1(c)	any remaining money purchase schemes	5,000-19,999	30 June 2025
1(c)	schemes without money purchase benefits, other than public service pension schemes or parliamentary pension schemes	5,000-19,999	30 June 2025
1(c)	hybrid schemes	5,000-19,999	30 June 2025
1(d)	any remaining money purchase schemes	2,500-4,999	31 August 2025
1(d)	schemes without money purchase benefits, other than public service pension schemes or parliamentary pension schemes	2,500-4,999	31 August 2025
1(d)	hybrid schemes	2,500-4,999	31 August 2025
1(e)	schemes that provide collective money purchase benefits, whether alone or in conjunction with other benefits	all sizes	30 September 2025
1(e)	any remaining money purchase schemes	1,500-2,499	30 September 2025
1(e)	schemes without money purchase benefits, other than public service pension schemes or parliamentary pension schemes	1,500-2,499	30 September 2025
1(e)	hybrid schemes	1,500-2,499	30 September 2025
1(f)	public service pension schemes	all sizes	31 October 2025
1(f)	parliamentary pension schemes	all sizes	31 October 2025
1(g)	schemes without money purchase benefits	1,000-1,499	30 November 2025
1(g)	any remaining hybrid schemes	1,000-1,499	30 November 2025
1(g)	any remaining money purchase schemes	1,000-1,499	30 November 2025

Part 2: medium schemes and providers

Cohort	Scheme type	Number of relevant members at reference date	Connect by
2(a)	relevant occupational pension schemes	750 – 999	31 January 2026
2(a)	FCA-regulated operators of a personal pension scheme, stakeholder pension scheme, a retirement annuity contract, a pension buy-out contract including a ‘section 32’ buy-out policy[footnote 4](#_edn4) or an FSAVC	4,999 and below	31 January 2026
2(b)	relevant occupational pension schemes	600 – 749	28 February 2026
2(c)	relevant occupational pension schemes	400 – 599	31 March 2026
2(d)	relevant occupational pension schemes	320 – 399	30 April 2026
2(e)	relevant occupational pension schemes	250 – 319	31 May 2026
2(f)	relevant occupational pension schemes	195 – 249	30 June 2026
2(g)	relevant occupational pension schemes	155 – 194	31 July 2026
2(h)	relevant occupational pension schemes	125 – 154	31 August 2026
2(i)	relevant occupational pension schemes	100 – 124	30 September 2026

Connection deadline: 31 October 2026

 4. Additional information

4.1 Schemes brought voluntarily into scope of the 2022 Regulations

The Department for Work and Pensions recognises that there may be some trustees or managers of occupational pension schemes that have fewer than 100 relevant members at the reference date which wish to voluntarily connect to the pensions dashboards ecosystem and bring their scheme into scope of the 2022 Regulations. Any trustees or managers that wish to do so should refer to forthcoming guidance published by the PDP.

4.2 New schemes

If an occupational pension scheme does not exist at the reference date but comes into existence on or after 1 April 2024 (and meets the threshold for connecting to the pensions dashboards ecosystem after the reference date), trustees or managers should connect their scheme by either six months from the end of their first scheme year, or the assigned date that applies to schemes of similar size and type as set out in the guidance, whichever is later. They must also have regard to the guidance.

4.3 Changes of administrator – applications to defer connection

It is recognised that changing administrator can be a significant process, which in some circumstances may require the transfer of data relating to millions of memberships. In these circumstances it may be excessively burdensome to connect to the pensions dashboards ecosystem by the dates set out in this guidance. Provided that connection is completed before 31 October 2026, it is not a requirement in the 2022 Regulations to make a formal application to defer connection if trustees or managers do not believe it is possible to connect by the dates set out in this guidance because of a change of administrator. It is recommended, however, that trustees or managers should communicate their plans with the PDP and TPR at the earliest opportunity.

The Department for Work and Pensions has issued guidance for trustees or managers of occupational pension schemes that meet the criteria set out in regulation 17 of the 2022 Regulations that may wish to apply to defer the connection deadline of 31 October 2026. This guidance can be found on gov.uk.^{[footnote 5]}

In having regard to the timetable set out in section 3 of this guidance, DWP would encourage trustees or managers which are changing administrator to review the guidance on deferred connection, even if they are not required to make a formal deferral application under Regulation 17. Whilst this is not a requirement under the 2022 Regulations, the deferred connection guidance sets out useful information that trustees or managers may wish to consider. In particular, whether changing administrator creates a disproportionate burden, or whether there may be alternative ways of connecting in line with the timetable in section 3 of this guidance.

The FCA has powers under the Financial Services and Markets Act 2000 to grant waivers and modifications to providers subject to its Rules. Firms that wish to apply to waive or modify the connection deadline (or other elements of the pensions dashboards Rules) for some or all of their pensions in scope of the FCA’s Rules, must:

1. state which waiver or modification is sought and why;
2. demonstrate how complying with the connection deadline would be unduly burdensome or not achieve its purpose; and
3. evidence how granting a waiver would not adversely affect the FCA’s objectives of protecting consumers, enhancing market integrity, and promoting competition.

4.4 Other considerations

Whilst it is not mandatory, adhering to the dates in the staged timetable for connection would provide the Pensions Dashboards Programme with adequate time to assist and co-ordinate activities to support the connection of schemes and providers in advance of 31 October 2026 and successfully deliver pensions dashboards. Connecting by the dates set out in this guidance also has additional benefits to schemes and providers which include:  

• being placed in a good position to achieve compliance by agreeing a practical delivery plan with their suppliers;
• sufficient testing time to enhance their members’ experience of using pensions dashboards; and
• demonstrating good governance and robust risk management.

The staged timetable for connection provides a ‘connect by’ date each month for different cohorts, but the connection of an entire cohort will require the connection of multiple entities. It will therefore be necessary to cooperate with PDP (in line with the general cooperation requirement set out in regulation 14 of the 2022 Regulations and COBS 19.11.5 in the FCA Handbook) to agree the precise timing of that connection within that month. In practice, this may be via an ISP or third-party administrator through which the scheme or provider is connecting.

In the event that a trustee or manager, or a pension scheme provider, has missed its relevant ‘connect by’ date (as set out in this guidance), it will also be necessary to cooperate with the PDP to find a new connection date. Missing the connection deadline of 31 October 2026 may result in enforcement action by the relevant regulator.

For trustees or managers and pension scheme providers using a third-party organisation (such as an administrator or ISP) to facilitate connection, it is important to agree with the third-party what is required and ensure this is completed well before the relevant ‘connect by’ date set out in this guidance.

1. https://www.thepensionsregulator.gov.uk/en/trustees/contributions-data-and-transfers/dashboards-guidance/preparing-to-connect-checklist ↩

2. Schemes with 100 or more members (which are not pensioner members) on the reference date or any subsequent date thereafter. ↩

3. that was approved under section 32 of the Finance Act 1981 (when that Act was in force) ↩

4. that was approved under section 32 of the Finance Act 1981 (when that Act was in force) ↩

5. https://www.gov.uk/government/publications/pensions-dashboards-guidance-on-deferred-connection ↩