The next stage of the Pension Dashboard Programme’s consultation into the delivery of the dashboard has arrived and it is the first since the mandating of the dashboard by the Pension Schemes Act. Sadly , we continue much as we did in 2020 with a series of consecutive investigations , each of which takes an exhaustive amount of time.
The current investigation is into the identity service, our digital fingerprint that sits at the heart of the dashboard
The diagram above shows just how much of a task lies ahead of the Pension Dashboard Program and – more worryingly – how little of the architecture is in place ready for testing.
While the dashboards themselves can be created in a few weeks , the linking of pension schemes to integrated service providers , the integration of State Pensions and the process of consent and authorisation (dependent on the identity service) are still to be consulted on, let alone built, integrated and tested.
Testing will ask questions over data quality and whether it can flow through the ISPs to the dashboards when identified , consented to and authorised. PASA are urging schemes to get on with testing their data and I look forward to seeing their proposals on how this can be done.
Testing needs to be done now and not when the dashboard infrastructure is in place. The dashboard is in danger of becoming an albatross around the DWP’s neck unless a way can be found to deliver much of the forthcoming timetable in parallel rather than one consultation at a time.
Schemes should be thinking about what they consider a quality standard that makes them dashboard ready, we should be looking at ways of accessing our state pension entitlements without unlocking Government Gateways, and we should be having an agreement on what the dashboards can do in terms of data displayed and how these link to actions savers might want to take.
I share with many others on the tech side of the argument, that the current pace is unlikely to deliver, even to the four year delayed target of 2023.
A reasonable proposal
There is an alternative way to achieve much of what the dashboard will achieve, but quicker. It will not deliver all that the dashboard could deliver once it reaches its availability point but it can do most of it in acceptable timeframes.
The FCA are currently consulting on Open Finance. Many organizations including Open Finance UK have responded welcoming the pensions dashboard. UK Finance are keen that matters move faster
UK Finance suggests as a priority that the FCA works with industry to develop a timeline of activity, and would welcome the opportunity to work with the FCA on the matter.
Why not hand Open Finance UK the opportunity to consider how pensions could reasonably be included in the Open Finance Initiative by creating open data standards that could be adopted by the 12 organizations that Romi Savova has identified as holding 80% of UK pensions data?
While these 12 could be getting on with providing feeds to data aggregators such as MoneyHub who already provide access to banking data using the CMA standards, the process of building the dashboard could continue.
This would have the immediate advantage of giving people access to the majority of the data quickly and would ease pressure on the DWP who clearly feel they need to go at the current pace to meet the exacting standards they have set themselves when establishing their Governance register a couple of years ago.
The alternative may be even more unpalatable to the big 12 providers than becoming part of open finance. The demand for relevant data from savers into UK pensions may be met, though market disruption , hinted at on a post today from Ian McKenna
It is in everyone’s interests that we get the dashboard over the line, but it may be best to leave it to its own devices for now, and focus instead on open finance, open pensions and the digitization of the customer experience