A key thing we know, from decades of pensions dashboards operational experience in continental Europe, is that, once launched, dashboards will definitely need to change.
Continental experience
In the summer of 2023, acting Chair of the new Dashboard Operators Coalition (DOC), Richard Smith, went on a research tour visiting the five country teams who have been operating dashboards for well over a decade. Richard said:
“All the dashboard teams I met (in Brussels, Copenhagen, Oslo, Stockholm, and The Hague), told me it’s only once dashboards are live and being used at scale that feedback really flows in from different types of users about the numerous changes they want to see to how dashboards work.”
All five of the dashboards in Belgium, Denmark, Norway, Sweden and The Netherlands have developed and changed enormously since they were originally launched. Changes are based on extensive user feedback so that the dashboards better meet users’ needs continually over time.
DAP isn’t the end, it’s the start
In the UK, Government and Regulators agree, continually stating that dashboards will iterate and improve over time, with richer data and deeper functionality, once they are launched.
Many people have heard of the Dashboards Available Point (DAP), i.e. the date from when dashboards will be available to the UK general public.
But the DAP isn’t the end of the dashboards programme. On the contrary, it’s just the start of a never-ending continual process of improvement of dashboards so that different types of UK consumers have a better and better experience of dashboards over time.
How flexible are the rules for front-end dashboards to support post-launch change?
In the UK, there’s quite a lot of Governmental and Regulatory control over commercial dashboards (which we know from international evidence will be, by far, the dashboards which most consumers choose to use, due to their ease, functionality, and wider open-finance links).
Commercial dashboards in the UK are regulated by three complementary sets of controls:
Department for Work and Pensions (DWP) Regulations
Description
DWP Primary legislation (Pension Schemes Act 2021 Section 118) and Secondary legislation (Pensions Dashboards Regulations 2022 Part 2)
What is the change mechanism?
Parliament must debate all changes to Primary legislation, and also all changes to the Pensions Dashboards Regulations (through the affirmative procedure)
Financial Conduct Authority (FCA) Rules
Description
FCA Handbook Conduct of Business (COB) Rules which apply to FCA-authorised Pensions Dashboard Service (PDS) firms*.
What is the change mechanism?
FCA Rule Review Framework which defines how FCA monitor and review how well their Rules are working in practice
PDP Standards
Description
Pensions Dashboards Programme (PDP) Standards from the Money & Pensions Service (MaPS)**
What is the change mechanism?
MaPS PDP Standards governance framework envisaging minor changes every six months and major changes every year
* As at Spring 2024, the FCA is consulting on draft PDS COB Rules with an aim of publishing settled Rules in Q4 2024
** PDP published updated Data Standards on 30 April 2024, but PDP’s other six sets of Standards (Design, Technical, Reporting, Security, Service and Operational) are all currently draft
So what will need to change, post-launch?
We don’t know, and the continental experience is that we won’t know until dashboards are launched and consumers of different types start giving live feedback.
This is why the four DOC member firms (Just Group, Legal & General, Moneyhub and Standard Life, part of Phoenix Group) are so keen for dashboards to be launched as soon as possible so that we can start hearing consumers’ live usage feedback and their requests for enhancements.
Examples of consumers’ possible requests for change
Here are a couple examples of things consumers might say once dashboards are live:
“The journey steps when I use a pensions dashboard are too confusing and too wordy”
To improve the journey steps, and make dashboards more usable for consumers, would definitely require changes to PDP Design Standards and quite probably to FCA Rules too
“To help me decide whether, and how, to consolidate my different defined contribution (DC) pensions, I really need to be able to see DC pension charges on dashboards”
To meet this need would definitely require changes to DWP Regulations and PDP Data Standards, and very likely to FCA Rules too
Of course, there are almost limitless things consumers might feed back, and a key role of the Dashboard Operators Coalition (DOC) will be to amass and sift all this rich consumer feedback. The DOC is well-placed to do this as it will represent providers of the most-used dashboards.
So the multi-faceted nature of dashboards regulation needs to be nimble
Richard Smith concludes: “So wherever the FCA Rules and PDP Standards settle initially, it is a certainty that they will need to change in light of live usage consumer feedback. DWP, FCA and MaPS PDP therefore all need to be nimble and make rapid changes to their Regulations, Rules & Standards so that dashboards can continue to work well for different types of UK consumers”.
All potential operators of commercial dashboards are welcome to join the Coalition, as they commit to offering their own pensions dashboards: please contact info@pdoc.org.uk
-Ends-
Notes to the editor
Organisations interested in finding out more about, or potentially joining, the Dashboard Operators Coalition (DOC) should contact info@pdoc.org.uk.
Contacts
Richard Smith Eleanor Ross
Chair, Dashboard Operators Coalition (DOC) Senior Account Director, Teamspirit
info@pdoc.org.uk eross@teamspirit.co.uk
M: +44 (0)7739 449 064 M: +44 (0)7393 758 446
About Just
Just (Just Group plc) is a FTSE-listed specialist UK financial services company. A leader in the individual retirement income, care and defined benefit de-risking markets, Just has been trusted to manage more than £26 billion of customers’ retirement savings and has helped customers release over £6.5 billion from their properties. Just provides a wide range of products, advice and professional services to individual customers, financial intermediaries, corporate clients and pension scheme trustees.
About Legal & General
Established in 1836, Legal & General is one of the UK's leading financial services groups and a major global investor, with £1.2 trillion in total assets under management (as at 31 December 2023) of which 40% is international. We have a unique and highly synergistic business model, which continues to drive strong returns. Legal & General provides powerful asset origination and management capabilities directly to clients, which also underpin our leading retirement and protection solutions. We are a leading international player in Pension Risk Transfer, in UK and US life insurance, and in UK workplace pensions and retirement income. Our purpose is to improve the lives of our customers and create value for our shareholders. Through inclusive capitalism, we are investing in long-term assets, such as real estate and infrastructure, that can help build a better society for the future.
About Moneyhub
Moneyhub’s goal is simple; to work with clients to improve the financial wellness of people, their businesses, and their communities. Hundreds of companies use our award-winning Open Banking and Open Finance technology to better understand their customers through data so they can comply with Consumer Duty, deliver them more suitable products, and automate money management or payments to ultimately increase their capacity to spend, save or invest more. To find out how to give the gift of financial wellness, and reap the rewards, visit www.moneyhub.com.
About Standard Life
Standard Life is a brand that has been trusted to look after peoples’ life savings for nearly 200 years. Today it proudly serves millions of customers who come to Standard Life directly, through advisers and through their employers’ pension scheme. Standard Life is part of the Phoenix Group, the largest long-term savings and retirement business in the UK. We’re proud to be building on nearly 200 years of Standard Life heritage together. Our products include a variety of Pensions, Bonds and Retirement options to suit people’s needs, helping our customers to invest and save for their future. We’re proud to offer a leading range of sustainable and responsible investment options. We support our customers on their journey to and through retirement with comprehensive, easy-to-understand guidance so they can invest in the right way for their needs, and plan a future they feel confident about. The value of investments can go down as well as up, and may be worth less than originally invested.