Issues affecting all schemes

Pensions dashboards – detailed requirements

The government has responded to its consultation on draft regulations setting out the detailed requirements for pension dashboards. The response notes that a number of changes will be made to the regulations in light of the consultation, including the following:

  • The staging deadlines for the first two cohorts (master trusts with 20,000+ active and deferred members and DC schemes being used for automatic enrolment with 20,000+ active and deferred members) will be deferred by two months.
  • The provisions around how the staging deadline for a hybrid scheme is determined will be changed so that the scheme would total the active and deferred members across both the DC and DB sections and treat the entire membership as a DB scheme to determine the staging deadline.

The Pensions Dashboard Programme (PDP) is also consulting on the standards that schemes will need to comply with in relation to pension dashboards. The consultation closes on 30 August 2022.

For more information on both the government consultation response and the PDP consultation, please see our legal update.

In addition, the Pensions Administration Standards Association (PASA) has published guidance in relation to pension dashboards on:

  • Data accuracy – this provides a list of the various data sources available to accurately confirm if a member is alive or deceased, and their name, date of birth, address and NI
  • Pension values – this includes a checklist and guidance on understanding value data requirements and scheme readiness to meet those requirements and creating an action


Trustees should determine when their staging deadline will be. Once the final regulations are published, trustees and administrators should review them and update their dashboards preparation as necessary. They may find the PASA guidance helpful in this respect. They should also keep the progress of the PDP consultation under review.

Transfers – incentives and overseas transfers

The government and the Pensions Regulator have published a statement on the operation of the statutory transfer conditions that were introduced last year. The statement has been published in light of industry concerns around the incentives red flag and the overseas investments amber flag. The statement notes that:

  • The conditions are not intended to impose additional burdens on schemes or administrators, or to impact on standard business practices.
  • Most transfers are legitimate and can proceed with minimum intervention.
  • The conditions should have no impact on the process for transfers that, prior to the introduction of the regulations, would have caused no concern.

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