DWP dashboards consultation criticised over launch date proposals

Published on June 28, the consultation is designed to provide clarity on two areas concerning dashboards.

The first is the go-live date, known as the “dashboards available point,” and the second covers the sharing of information between The Pensions Regulator and the Money and Pensions Service.

It follows a previous consultation, launched in January, into draft dashboard regulations that was likewise met with criticism over the scale of the work it entailed for schemes, with the DWP’s insistence on both ‘find’ and ‘view’ functionality being available at launch deemed unfeasible by many industry commentators.

Schemes will have 90 days’ notice

The DWP acknowledged the feedback to its proposals in its new consultation, specifically the industry’s insistence that the dashboards available point be “carefully selected” and “be based on a range of criteria that have been carefully tested and goes beyond just achieving a certain level of coverage”. 

“The department expects the evidence which will shape the DAP criteria to emerge through private beta testing when the programme can test the service with invited users at scale,” the consultation explained.

The industry also said it would “value more certainty around the DAP to ensure schemes are prepared for an increase in queries, can cope operationally and can effectively manage communication to their members,” and that the eventual date should be agreed between the DWP, Maps, TPR and the Financial Conduct Authority.

The DWP also acknowledged the several respondents to the first consultation who questioned whether a phased, incremental approach to the DAP might not be preferable to a single launch date, leading the department to promise “a provision on the DAP within the pensions dashboards regulations”. 

“We want to give pension schemes, prospective dashboard providers and members of the public a further opportunity to provide meaningful feedback on the proposal,” it said.

It further committed itself to ensuring that the industry has “sufficient lead in time” between the announcement of the DAP and the point at which it occurs, with the secretary of state’s announcement of the date serving as “a final confirmation”.

“We therefore believe 90 days notice is sufficient as the point at which a final confirmation of the DAP is made,” it said.

Launch date proposals criticised

Though the industry has long been broadly supportive of the intent behind dashboards, the practicalities of delivering them and the DWP’s specific requirements have frequently met with criticism, and its plans for the launch date - or the “dashboards available point” - are no exception.

The date itself is not expected to be finalised until certain conditions have been met, principally having to do with dashboards coverage, and the collection of evidence pertaining to user understanding and experience.

Currently, it is expected dashboards will go live at some point in the summer of 2024, though the DWP has yet to set a firm date. 

DWP is missing the point with this consultation.Steve Webb, LCP partner

Dashboards will first go through an extensive beta testing regimen, but the expectation from the industry is that the plan is for a “big bang” switch-on that could potentially give schemes as little as 90 days' notice, which a number of industry experts have criticised for the unfeasible demands it entails.

LCP partner Steve Webb said the new consultation was in danger of “missing the point” by not ruling out such a “big bang” moment, which he said would entail a “surge” in demand and require much greater capacity and systems resilience than would be needed for a more gradual approach to the go-live moment.

He added that, once all users are able to access the dashboard, it will likely lead to a flood of queries to schemes that may not have the capacity to handle them.

“DWP is missing the point with this consultation. The big issue which DWP’s latest consultation ignores is whether there should be a ‘big bang’ switch-on of dashboards at all,” he said.

“If the whole project goes live on a single day there could be a huge spike in demand, especially if the launch attracts widespread media attention. Pension schemes may face real challenges in dealing with all the follow-up queries and engagement from members. 

“A phased approach, perhaps by age, would be much more sensible, allowing the whole system to bed in and proper plans to be made. As things stand, schemes may have just 90 days’ notice of a major call on their resources, and may find it very difficult to put in place the surge capacity to provide a positive user experience”.

There needs to be more join-up to understand how this will work.Kate Smith, Aegon

Kate Smith, head of pensions at Aegon, concurred, arguing that a 90-day lead-in “may work well for the public” but “doesn’t give the pension industry time to gear-up for any early surge in member queries”. 

“Some schemes and providers will be more ready than others. But all will have to plan resources well in advance to deal with the public’s initial demand which could be high due to promotion of the dashboards from the government and industry. There needs to be more join-up to understand how this will work,” she said.

“We want the public to have a good experience of dashboards from day one, not having to queue virtually to use it if they are caught in a log jam. This could lead to disengagement with some simply giving up or not returning. 

“A longer lead in, say of 6 months, along with a government and industry-wide promotion campaign is needed to ensure the dashboard ecosystem doesn’t fall over. This needs to be the priority after all the effort which has gone into building dashboards – to be successful the delivery needs to work for all.” 

Benjamin Mercer is a senior reporter at Pensions Expert, FTAdviser's sister publication