No more updates for scheme registrations within 6 month timeframe

The Association of Member-directed Pension Schemes (AMPS) has announced that it has been informed by HMRC that it will no longer provide updates for scheme registrations that have been outstanding for less than 6 months.  AMPS had previously advised member firms that it could assist with chasing up registrations where timeframes had been excessive.  If HMRC has not made a decision within 6 months of receiving a registration application, an appeal can be made to a tribunal as if HMRC had decided not to register the scheme.

Pensions dashboards latest

On 15 December the Pensions Dashboard Programme (PDP) published the key data standards which will underpin the initial technology and allow individuals to view their pensions via their chosen dashboard.  The PDP's Data standards guide is aimed at the technical audience responsible for working on pensions data and is designed to ensure that providers can prepare their data for onboarding to pensions dashboards.

On 2 March the Pensions Administration Standards Association (PASA) published guidance for scheme trustees on how to start getting ready for pensions dashboards.  The guidance says that trustees should already be making a plan to ensure that their data is "dashboard compliant".  Compulsory connection to the dashboards is due to happen in 2023, but it is intended to allow schemes to voluntarily connect to the dashboards in 2022.

In a separate development, on 13 May the Pensions Dashboards Programme (PDP) published a progress update report.  The report says that the dates on which pension schemes will be required to connect to the dashboard will need to be staged.  The PDP has been working with the Pensions Regulator, FCA and DWP to assess different options for deciding the order in which schemes are required to connect.  

On 27 May the PDP published a "staging call for input".  It proposes that schemes should connect to the dashboard in three "waves":

  • wave one: schemes with 1000 or more members (starting in April 2023 and running for up to two years);
  • wave two: schemes with 100 to 999 members (starting when the bulk of large schemes have already connected to the dashboard, unlikely to be before 2024);
  • wave three: schemes with less than 100 members.

The PDP recommends sub-dividing wave one into three distinct cohorts:

  • cohort one: master trusts and FCA-regulated providers of personal pensions, starting spring 2023;
  • cohort two: defined contribution schemes used for auto-enrolment, during 2023; and
  • cohort three: all remaining occupational schemes with 1000 or more members in order of size, with the largest defined benefit schemes to onboard in 2023.

The call for input closed on 9 July 2021.

APPT issues warning about scam signatures

The Association of Professional Pension Trustees (APPT) has warned about a scam which involves lifting signatures from publicly available documents such as statements of investment principles and chair's statements and using those signatures to obtain information or carry out fraudulent transactions.  The APPT suggests that versions of the documents that are published online should have signatures redacted or be type signed.

PSIG publishes revised code on combating pension scams

On 1 April the Pension Scams Industry Group (PSIG) published a revised version of its code of practice on combating pension scams which has been updated to include reference to various legal and regulatory developments since the original code was issued.

ICO publishes detailed right of access guidance on dealing with DSARs

The Information Commissioner's Office (ICO) has published detailed guidance on dealing with data subject access requests (DSARs).  The guidance is aimed at data protection officers and those with specific data protection responsibilities in larger organisations.

ICO publishes data sharing code of practice

On 17 December the ICO published a new Data Sharing Code of Practice.  The code is intended to be a practical guide for organisations about how to share personal data in compliance with data protection law.  The code is a statutory code of practice, meaning that the Information Commissioner must take the code into account when considering whether an organisation has complied with its data protection obligations.

Standard Contractual Clauses for data transfers: new developments

The European Commission adopted new EU Standard Contractual Clauses for EEA organisations transferring personal data outside the EEA on 4 June (New EEA SCCs). Following Brexit, transfers from the UK are subject to different rules.  The New EEA SCCs will not provide adequacy for transfers out of the UK as the UK is no longer in the EEA.  ICO guidance has stated that UK organisations exporting personal data can continue to use the previous EEA SCCs which existed at 31 December 2020 until such time as we have new UK SCCs (which may well follow the format of the New EEA SCCs).  In the meantime, UK organisations can choose to update the references in the previous EEA SCCs so they make sense in a UK context, for example, changing references to the UK GDPR, changing references to the EU or Member States, to the UK, and changing references to a supervisory authority to the ICO.  The ICO has produced a UK version, available on their website here.  

European Commission adopts adequacy decision for UK

The European Commission has adopted an "adequacy decision" which will allow the free flow of personal data between the UK and EU member states to continue while the decision remains in force.  The decision will expire on 27 June 2025, but may be renewed.  It may be suspended or amended before then if UK data protection law changes in such a way that the Commission considers that the conditions for an adequacy decision are no longer met.

IOPS consultation on good practices for pension projections

The International Organisation of Pension Supervisors (IOPS) has consulted on good practices for designing, presenting and supervising pension projections.  Its proposals include:

  • methodology and assumptions should be made available to the users and should be standardised as far as possible to allow different projections to be compared;
  • projections should be made available on providers' websites, with users able to modify assumptions to understand the range of possible outcomes;
  • projections should be personalised as much as possible to provide meaningful information to individuals;
  • projections should take into account costs;
  • forecasted values should be expressed in real terms and should present future lifetime monthly income rather than showing solely the value of accumulated assets;
  • government authorities and/or providers should engage in extensive testing to identify the ways of presenting projections that are best understood by users, and be ready to adjust them if issues are identified;
  • projections should clearly distinguish between guaranteed and non-guaranteed payments;
  • projections should be accompanied by information about decisions a user can take and the expected effect of those decisions (eg increasing contributions or postponing retirement); and
  • projections should be accompanied by information about tax treatment.

ABI report on supporting customer decisions about pension withdrawals

In its report "Future proofing the freedoms Supporting customer decisions about pension withdrawals" the ABI calls for changes to the rules around pension advice to enable pension providers to provide greater support to customers making withdrawals from their pension funds.  The report suggests ways in which firms can do more to support non-advised drawdown customers.  It suggests approaches such as additional personalisation, presenting filtered options based on customer circumstances.  However, it says that "this feels very close to the advice boundary".  The report says the ABI believes that accessing a pension is a special case which requires an alternative approach to the existing advice rules.

Key contact

Jade Murray

Jade Murray

Partner, Pensions
United Kingdom

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