PASA today published its combined response to the Pensions Dashboard Programme’s (PDP) consultation on draft mandatory design standards setting out how data must be presented to ensure a consistent and good user experience on dashboards and the Financial Conduct Authority’s (FCA) consultation on the proposed regulatory framework for operators of pensions dashboards.
Kim Gubler, PASA Chair, commented: “PASA set up its Pensions Dashboards Working Group (PDWG) in March 2017 and has been considering these issues in depth since this time.
As a number of our comments are thematic across several questions, we’re submitting this combined document of all our responses on both consultations. We’ve focused on the topics with most material impact on pensions administration.”
Richard Smith, Chair of the PASA Pensions Dashboards saver experience sub working group, commented: “There are a number of topics included in both the FCA and PDP consultations which are overarching, and our response includes some key takeaways on these subjects. Our response also includes answers to the specific consultation questions, which should all be read within the context of these key points, which are:
- As an overall approach, administrators being able to see test dashboards would’ve been better
- Qualifying Pensions Dashboard Service (QPDS) authorisation timing means wide-scale testing can’t start for quite a while yet
- Principles not prescription presents risks for administrators – testing will help illuminate these risks
- Recognition of the potentially significant impacts on administrators after savers have used dashboards
- PASA’s proposal for the best way forward
The PASA PDP and FCA Consultation response can be found here.
