In March 2023, the government announced that the staging timetable for connection to the pensions dashboards ecosystem would be delayed because more time was required to put the ecosystem’s central digital architecture in place. The staging timetable was based on scheme size and type and was originally due to begin in summer 2023. For more information on the delay announcement, please see our legal update.
The government has now laid draft regulations before Parliament for approval that replace the statutory staging timetable with a single connection deadline for all schemes of 31 October 2026. The government has separately announced that a revised staging timetable will be published in guidance. The government has not indicated when this guidance will be published.
The regulations also change the date to be used for the purposes of determining whether a scheme is subject to the dashboards requirements – known as the “reference date”. Currently, all schemes with 100+ active and/or deferred members as at the scheme year end date falling between 1 April 2020 and 31 March 2021 are subject to the dashboards requirements. The regulations change the reference date to the scheme year end date falling between 1 April 2023 and 31 March 2024. This may mean that some schemes which were previously out of scope are now in scope and vice versa.
For more information, or advice in relation to the pensions dashboards requirements, please speak to your usual Mayer Brown contact.