DWP has today published a new consultation on two issues relating to pensions dashboards – the way in which the ‘go-live’ date to the public will be announced, and on communications between the Money and Pensions Service (MAPS) and the Pensions Regulator.
But on the ‘go-live’ date – known in the jargon as the ‘Dashboards Available Point’ (DAP) – DWP is ‘missing the point’ according to LCP partner Steve Webb.
According to the consultation, DWP will not finalise the go-live date until certain conditions have been met in terms of coverage and evidence of user understanding and experience, though some broad indication will be given as to the likely date. When it finally decides, DWP proposes that schemes may have as little as 90 days’ notice of the final go live date. Current expectations are that this may be in summer 2024, though there has yet to be any official indication of the intended date.
Although the consultation makes brief mention of the suggestion of a phased go-live, there is no indication that the Department is planning anything other than a ‘big bang’ switch on, albeit following a period of extensive ‘beta testing’.
According to Steve Webb, partner at LCP, a sudden switch-on of dashboards could cause huge headaches to pension schemes and pension providers and could also be a negative experience for users.
With a ‘big bang’ switch-on, the dashboard infrastructure could face a huge ‘surge’ in demand, needing much greater capacity and resilience than would be needed for a more gradual process. In addition, once users see their data it is likely to lead to a surge in queries to schemes, who may not be able to cope with the demand.
The sorts of questions prompted by a dashboard could include:
- ‘where is my pension?’ in cases where a worker expects to see a pension but it is not on the dashboard, perhaps because of issues around identity verification;
- ‘what is this pension?’ in cases where a worker sees a pension they did not expect, perhaps because the name of a scheme or employer has changed, or even because they are seeing a ‘false positive’ – a pension which is not actually theirs;
- ‘why is the figure on the dashboard different to my last statement?’ – dashboards will have their own definitions which will often not be the same as those used on statements;
- ‘what are my options?’ – members who see all their pensions may well want to take action, such as consolidating their pensions, and servicing this demand could cause strain on schemes.
Commenting, Steve Webb, partner at LCP said: “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.
“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.”