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The Pensions Brief: July 2022 – Employee Benefits & Compensation

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Issues affecting all schemes

Pensions dashboards – detailed requirements

The government has responded to its consultation on draft
regulations setting out the detailed requirements for pension
dashboards. The response notes that a number of changes will be
made to the regulations in light of the consultation, including the

  • The staging deadlines for the first two cohorts (master trusts
    with 20,000+ active and deferred members and DC schemes being used
    for automatic enrolment with 20,000+ active and deferred members)
    will be deferred by two months.

  • The provisions around how the staging deadline for a hybrid
    scheme is determined will be changed so that the scheme would total
    the active and deferred members across both the DC and DB sections
    and treat the entire membership as a DB scheme to determine the
    staging deadline.

The Pensions Dashboard Programme (PDP) is also consulting on the
standards that schemes will need to comply with in relation to
pension dashboards. The consultation closes on 30 August 2022.

For more information on both the government consultation
response and the PDP consultation, please see our legal update.

In addition, the Pensions Administration Standards Association
(PASA) has published guidance in relation to pension dashboards

  • Data accuracy – this provides a list of the various data
    sources available to accurately confirm if a member is alive or
    deceased, and their name, date of birth, address and NI

  • Pension values – this includes a checklist and guidance
    on understanding value data requirements and scheme readiness to
    meet those requirements and creating an action


Trustees should determine when their staging deadline will be.
Once the final regulations are published, trustees and
administrators should review them and update their dashboards
preparation as necessary. They may find the PASA guidance helpful
in this respect. They should also keep the progress of the PDP
consultation under review.

Transfers – incentives and overseas

The government and the Pensions Regulator have published a
statement on the operation of the statutory transfer conditions
that were introduced last year. The statement has been published in
light of industry concerns around the incentives red flag and the
overseas investments amber flag. The statement notes that:

  • The conditions are not intended to impose additional burdens on
    schemes or administrators, or to impact on standard business

  • Most transfers are legitimate and can proceed with minimum

  • The conditions should have no impact on the process for
    transfers that, prior to the introduction of the regulations, would
    have caused no concern.

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article provides information and comments on legal
issues and developments of interest. The foregoing is not a
comprehensive treatment of the subject matter covered and is not
intended to provide legal advice. Readers should seek specific
legal advice before taking any action with respect to the matters
discussed herein.

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