At last, after years of build-up the Dashboard regulations finally came into force on 12 December.  And with the first staging date (for large DC master trusts) now less than nine months away there is lots for all schemes to do and think about. 

I’m going to highlight a few tricky areas with some subtleties to think about when it comes to connection. 

• Dashing ahead 

Where employers have legally separate schemes that have a strong correlation in membership such as a legacy DB-based scheme and a newer DC scheme it would make sense to discuss with the scheme trustees whether to consider staging them together since doing so may make for a more efficient connection process.  And further down the line it may lead to a better holistic experience for employees if all their pensions from their employer are available to view on the same date. 

We expect that early applications for connection will generally be viewed positively by the regulatory authorities since it will lead to greater dashboard coverage at an earlier date.  However, trustees need to apply at least two months before the earlier connection date they want to use.   

• Seeking to delay boarding? 

Understandably with everything else going on at the moment both in pensions and the wider economic sphere, employers and trustees may be reluctant to invest time and effort in connecting to dashboards and be wondering if it’s possible to delay doing so.  The good news is that if the scheme already has a programme in place to transfer scheme data to a new administrator or they have already entered into a contract to retender the administration of the scheme then it may be possible to apply for deferral.  However, there is only a twelve-month window to make such an application and this started from when the regulations came into force on 12 December, so any trustees interested in this should push it to the top of their agenda.  But it is clear from the recently published guidance that DWP will not be inclined to grant deferrals easily since this goes against the policy intention of getting as many people connected to Dashboards as soon as possible.  So, it is not certain that any application for deferral will be successful. 

Other than these changes in scheme administration, there are no other grounds to apply for deferral so if on 12 December there were no such plans in place then no deferral will be possible – which is another reason to make sure that trustees have robust plans in place to connect on time. 

• Is this a wind-up? 

Following on from the above point – and one that is of considerable interest to several clients – is what are the connection requirements for schemes that are winding up? 

The answer to that is that there is no exemption for wind-up because DWP believes that this is a drawn-out process which can take years to complete.  So, schemes that are currently, or are considering, winding-up need to be 100% certain that this will be complete before their connection date and/ or have a project plan to connect - like any other scheme – at the required date.  However, there is a small easement to the data that schemes winding-up may have to provide in response to data requests. 

I’ve given an overview of these issues but please note that there are further technical details which I haven’t gone into in this short blog.  But do please get in touch with your regular LCP contact or me if you’d like to discuss these points further. 

More in this series:

You’ve got mail! Pinning down your dashboards staging date

Dashboard Lasagne: Pension Dashboard preparation is key or it’s a recipe for disaster!