On 25 March 2024, the Government published guidance setting out the dates by which it expects schemes to connect to the pensions dashboard.  The guidance applies both to trustees of occupational pension schemes and to providers of personal pension schemes.  Legally the deadline for connecting is 31 October 2026.  However, trustees and pension scheme providers are required to "have regard" to the guidance and, in the absence of exceptional circumstances, the Government expects schemes to aim to connect by the deadlines in the guidance rather than waiting until the strict legal deadline.  

The guidance says that trustees and providers should be able to demonstrate how they have had regard to the guidance.  This includes keeping audit trails of decisions made, reasons for them and actions taken. 

The connection dates set out in the guidance vary by scheme size and type.  Some key connection deadlines include:

• 30 April 2025 for master trusts providing money purchase benefits only with 20,000 or more relevant members;
• 30 April 2025 for FCA-regulated operators of a personal pension scheme, stakeholder pension scheme, retirement annuity contract, pension buy-out contract (including a "section 32 policy") or FSAVC where the number of relevant members is 5000 or more;
• 31 May 2025 for money purchase schemes used for automatic enrolment with 5000 or more relevant members;
• 31 May 2025 for schemes with 20,000 or more relevant members where the scheme is a private sector defined benefit scheme or a hybrid scheme; and
• 30 June 2025 for most schemes with 5000-19,999 relevant members that are not subject to an earlier deadline.

For occupational schemes, the number of relevant members is to be determined at the scheme year end date in the period between 1 April 2023 and 31 March 2024.  Pensioners are not "relevant members" for this purpose.  FCA-regulated pension providers should determine number of relevant members by  counting the number of pots in accumulation across all relevant pension schemes the provider operates.  This should be as at the scheme year end date in the period between 1 April 2023 and 31 March 2024.  (The guidance does not specify what happens if different schemes have different year ends.)

The Pensions Regulator (TPR) has updated its pensions dashboards guidance to reflect publication of the Government's connection dates guidance.  TPR says it recognises that delivering pensions dashboards is a huge challenge for industry and that as a regulator it will take a pragmatic and proportionate approach.  However, it will take action if it sees intentional or reckless non-compliance.

Our thoughts

A previous version of the pensions dashboards regulations did set out a series of legally binding connection dates, but the legislation was altered when the Government effectively acknowledged that the timetable set out in those regulations was not achievable.  Whilst the only legally binding connection deadline is 31 October 2026, the Pensions Regulator/FCA are unlikely to be sympathetic to trustees or providers that miss the legal deadline if no serious attempt has been made to comply with the deadlines set out in the guidance.

Even the earliest deadline set out in the guidance falls after the date of the next General Election.  However, given how far the dashboards project has progressed, we think it unlikely that any future government will seek to abandon the project.