We are pleased to share a summary of our feedback in response to the Financial Conduct Authority's (FCA) further consultation on the regulatory framework for pensions dashboard service (PDS) firms (CP24/4). Our feedback underscores our commitment to improving the pensions landscape for consumers and exemplifies our ongoing engagement with key stakeholders.
Aligning with Draft Perimeter Guidance
We are pleased to confirm that the Draft Perimeter Guidance (PERG) aligns well with our expectations and supports the primary delivery models envisioned by Moneyhub, which we have actively discussed in prior consultations with the FCA. This alignment is particularly seen in FCA’s Illustrative scenarios 1 & 2, which reflect the operational blueprints that we believe will best serve the market’s needs.
Advocating for Consumer Control through Choice Architecture
In the spirit of enhancing consumer empowerment, we recognise the potential benefits of the proposed Choice menu architecture. However, we stress the importance of thorough consumer testing of screen and app designs by prospective PDS firms. We propose that the final FCA Handbook Rules maintain enough flexibility, allowing firms to effectively balance consumer ease of use with necessary consumer and data protection controls.
Addressing Post-Launch Regulatory Adaptability
Based on the universal experiences from European pensions dashboards, we highly recommend an adaptable approach post-launch. Recognising the importance of continual evolution through feedback, Moneyhub urges the DWP, FCA and MaPS PDP to embrace regular updates to their respective Regulations, Handbook Rules and Standards respectively.
The Critical Need for Pace
We are concerned about the delayed timelines for publishing finalised PDS Handbook text and subsequently opening the PDS authorisations gateway. It’s clear from international implementations, especially from Norway, that consumers need and want to use commercial pensions dashboards as soon as possible.
Working with the other member firms in the newly formed Dashboard Operators Coalition (DOC), Moneyhub is aiming to collaborate with the DWP, FCA and MaPS PDP to help bring a number of pensions dashboards to UK consumers as soon as possible. A key start in this process is the DOC’s 8 Step Pathway to a Flourishing Dashboards Universe policy paper developed in April 2024.
Responses to FCA's Specific questions
In further sections of our response, we address specific questions posed by the FCA:
On Perimeter Guidance:
We are pleased to see the FCA’s Draft Perimeter Guidance (PERG) for operators of pensions dashboards. It is as we expected and supports both the main delivery models Moneyhub envisages emerging in the market (which we have previously discussed with the FCA).
On Choices Architecture:
The FCA’s choices menu proposals could potentially work well for consumers, but much will depend on the results of detailed consumer testing of screen / app designs by potential PDS firms, and .
We agree that a user must have knowledge of how their data will be passed on as they move between features in the pensions dashboard space. They must be able to remove that consent at any time via the centralised consent space mentioned in the design standards.
It is important that there is sufficient flexibility in the final FCA Handbook Rules to allow PDS firms to strike the right balance between friction and ease for onward customer journeys.
On Exit Communications:
We propose streamlining communications to avoid overwhelming consumers, based on our research, which shows clear consumer understanding during entry and exit phases of PDS interactions.
Specifically, we propose the removal of the need for messaging between pensions dashboards and any contact method provided by administrators. As stated in the consultation draft, this movement out of a pensions dashboard is apparent from the context in which the link was presented. There will also be other signs, such as: a change in branding, tone of voice and many others - including a new tab or window depending on the user's settings.
We agree users should be aware when they are travelling between different areas of regulation. However, evidence shows that users are already aware of this movement.
On Delegated Access:
We recommend postponing decisions on these until there is more clarity on the functionalities to be delivered by MaPS PDP.
We would like to encourage further regulations to provide definitive understanding of when something is mandated, and the precise details of all involved from all groups involved. This should be clearly defined vs when something is optional and which other applicable standards would be applied.
The scenario of delegated access is one - we do not yet have an understanding of the journey a user will be expected to take and so we cannot pass comment on this proposal.
On Data Export:
We want a fair, easy to understand and use solution for end users of pensions dashboards. For some that will be continuing a relationship with their existing provider. Given the guidance on messaging included in this consultation, we think the user would have the opportunity to explore other competitive options should they wish to do so.
We would like to emphasise that seeing Pensions on their own is not very helpful for most people and definitely not helpful for the people who are most likely to need a pensions dashboard in the coming years. People need to be able to see their pensions in the context of other investments and property as well as their lifestyle and spending habits. Our testing has shown that the ability to add pension data to other data sources to complete a holistic view is the most essential next step and a prerequisite to the consumer being able to get comprehensive advice and improve their overall financial wellness.
Conclusion and Continued Collaboration
Moneyhub remains steadfast in our commitment to facilitating a smoother, consumer-friendly pensions dashboards ecosystem. We eagerly anticipate further collaboration with the FCA and other stakeholders within the Dashboard Operators Coalition (DOC) to ensure that UK consumers can benefit from a well-regulated, efficient, and user-centric range of different pensions dashboards services.
As part of our ongoing dialogue with regulators and industry partners, we look forward to contributing to an evolving regulatory landscape that best serves the interests of all parties, especially the consumers.
If you’d like to see a copy of our response in full, you can request one by sending us an email →