The Pensions Regulator says failure to meet UK pensions dashboards' duties is 'not an option'

The Pensions Regulator (TPR) has published its new dashboards compliance and enforcement policy. This sets out TPR's expectations of trustees and scheme managers to comply with their pensions dashboards duties, and the action TPR will take if they do not.

Highlighting the new policy, the messaging is clear from a recent blog by TPR: "Act now, so we don't have to."

Investigative and enforcement action

If it identifies or suspects a breach of legislation, the policy cautions that TPR can take both investigative and enforcement action, potentially including issuing compliance notices and penalty notices. The approach taken will depend on factors such as the nature and scale of the impact on members and on whether the breach is the result of circumstances within the scheme's control.

TPR's hope is that enforcement action will not be required and that schemes will take timely measures to prepare for dashboards. However, it warns: "Before we know it, pension dashboards will result in a huge wave of savers interacting with their personal data. Failure to meet your duties is therefore not an option."

A crucial step for schemes in preparing for dashboards is ensuring that they have complete and accurate data. In its blog, TPR has confirmed that it would start reaching out to schemes this autumn, asking them to explain how they are measuring and improving their data. Any schemes failing to meet its expectations may be the subject of enforcement action.

Schemes should prepare

With the publishing of its compliance and enforcement policy, TPR is clearly hoping to remind schemes of the importance of preparing for dashboards and spur into action those schemes that have been slower "off the blocks".

Although the long-stop deadline for dashboards connection is 31 October 2026, the connect-by dates for most schemes fall in 2025 and earlier in 2026 and there are a number of steps schemes can and should be taking now to prepare for connection and to reduce the risk of TPR invoking its enforcement powers against them.

Osborne Clarke comment

For schemes preparing for connection to dashboards, we can:

• Provide trustee training on legal requirements relating to pensions dashboards.

• Help you scope out a data cleanse and audit project, working with your scheme administrator.

• Review and update your scheme's privacy notice and data protection policy to ensure that you have appropriate lawful grounds for processing.

• Help you draft or update your IT, cyber security and data monitoring policies to ensure they address the issues raised by sharing data with the pensions dashboards.

• Review your contract with your scheme administrators and/or software providers, and ensure you have contractual protection against penalties relating to non-compliance with the dashboard requirements and/or any data breaches.