Pensions Bulletin 2023/09

Our viewpoint

Government announces pensions dashboards delay

Laura Trott, the Pensions Minister, has announced in a ministerial statement that there will be a reset of the deadlines by which pension schemes must connect with the pensions dashboard, as set out in DWP regulations and FCA rules.  The reason given is that “additional time is required to deliver the complex technical solution to enable the connection of pension providers and schemes”.

The extent of the delay is unknown at this stage, with Laura Trott saying that she will provide a further update to Parliament before the summer recess.  Once the new timetable is known the DWP will need to lay amending regulations and the FCA will need to adjust its rules.

Her statement concludes by saying that the Government remains thoroughly committed to the delivery of pensions dashboards and that “it is essential that scheme preparation for pensions dashboards continues”.

Separately, the Pensions Dashboards Programme has announced that it is working with the DWP to establish “a new and achievable plan for delivery”.  The Pensions Regulator has also said that it will update its initial guidance shortly “to reflect this announcement and provide clarity on how schemes should continue preparing for dashboards”.


This news is not entirely surprising as stories had started to emerge in the early New Year that all was not well with the implementation.  What is worrying is that the Government is not attempting to quantify the likely delay.  However, it seems likely that it will be at least 3 months and quite possibly a lot longer.

The Government is also not giving any detail as to what exactly the issue is, but it would seem to be something to do with the IT ecosystem, rather than the preparedness of those schemes that will be first to connect.  The PDP in its release talks of the “need to do more work to ensure the connection journey is stable and secure”, suggesting that the challenge of matching many thousands of requests each day with millions of pension records is throwing up a number of issues.

For pension schemes generally this news provides unexpected additional time to prepare, including on such matters as data cleansing, which will be welcomed.  The connection timetable had been challenging in any event, notwithstanding the technical difficulties being faced by the Pensions Dashboards Programme that have now been acknowledged.

The Government now has a difficult role to fulfil.  The lack of a firm new timetable risks leaving the industry in limbo, but the Government cannot realistically set out a new timetable until it knows that the IT issues have been resolved.

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Auto-enrolment extension to go ahead at last

A Private Member’s Bill proposing certain extensions to current auto-enrolment law, has been replaced by a Government-backed Private Member’s Bill which is to be the vehicle for the Government delivering on its 2017 auto-enrolment review conclusions (see Pensions Bulletin 2017/53).

The Pensions (Extension of Automatic Enrolment) Bill was first published in February 2022, but has been in a state of limbo ever since (see, for example, Pensions Bulletin 2022/08).  It was due to have its long-delayed Second Reading on 17 March, but instead it has been withdrawn and replaced by the Pensions (Extension of Automatic Enrolment) (No. 2) Bill which had its Second Reading on 3 March.  This new Bill in essence delivers what the first Bill had proposed, but in a form that is more to the Government’s liking.

As before, the Bill proposes the following:

  • A reduction from 22 in the lower age limit from which the employer duty to auto-enrol applies – but with regulations now able to set this lower age. The policy intent is to reduce the lower age limit to 18
  • The potential removal of the lower limit of the qualifying earnings band (currently £6,240 pa) within which minimum contributions are determined, so that contributions are calculated on all earnings up to the upper limit of the band (currently £50,270 pa). Regulations are able to deliver on the detail which could allow for the lower limit to be reduced for a period of time ahead of its potential removal

The new Bill also enables regulations to modify the requirements of the annual review of the qualifying earnings band and for any changes to be introduced following a period of consultation with interested parties.

Announcing this development, the DWP said that the provisions in the Bill would not result in any immediate change.  The press release was also silent on any potential timeline.


Having prevaricated on the implementation for over five years the Government is at last starting on the necessary legislative journey.  This is good news for younger workers who will be able to join pension schemes sooner and for those on low earnings, such as part-time workers, who will be able to build up pension savings more quickly.

The Bill itself will likely be fast-tracked through Parliament and hopefully we will start to see implementation proposals before the end of this Parliament.  As there are Exchequer costs associated with this decision (in particular, the tax relief on employer and employee contributions), we will not be surprised to see this policy decision get a mention in next week’s Budget.

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FRC goes ahead with its refreshed TAS 100

The Financial Reporting Council has finalised its reworking of changes to Technical Actuarial Standard 100 and two accompanying guidance documents following a consultation launched last June (see Pensions Bulletin 2022/24).  The new TAS 100 suite, which introduces a new principle relating to risk identification, applies to technical actuarial work that is completed on or after 1 July 2023.

As little change has been made to the structure as a result of the consultation, the new TAS 100 remains arranged as a set of mandatory Principles, followed by Application statements that set out regulatory expectations, any material deviation from which must be justified.  The non-mandatory guidance then builds on this in two areas.

The FRC remains of the view that its new TAS 100 should not result in any significant additional ongoing burden on practitioners.  But to give effect to this, and following concerns expressed by a number of practitioners, the FRC has made many drafting adjustments.  These are welcome as their purpose is to clarify that practitioners should continue to apply proportionality and judgment to guide their compliance activities.

There is no news on the topics for future guidance which had been promised at the time of the June 2022 consultation.


All actuaries will now need to assimilate the messages contained within this very different-looking actuarial standard to that currently in force.  The unchanged structure may well prove a challenge and risk a tick-box culture developing – something the FRC says that it wants to avoid.

Hopefully, the drafting changes that have been made as a result of the consultation will make the new standard more workable.  That certainly seems to be their aim, a number of which have significantly toned down, or otherwise removed, what were clearly unworkable requirements.  But there is no doubt that the FRC has replaced a very high level and principles-based standard that could be readily internalised into actuarial thinking, by something that has the look and feel of rules that must be obeyed.  It is not obvious that this is either needed or will improve the quality of actuarial work.

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Technical adjustments to PPF and Fraud Compensation legislation to go ahead

The DWP is going ahead with proposed technical amendments to the legislation governing the operation of the Fraud Compensation Fund (FCF) and the Pension Protection Fund (PPF) on which it consulted in August 2022 (see Pensions Bulletin 2022/31).  As before they:

  • Insert an additional prescribed liability that the PPF Board can make an interim payment for in order to cover scheme fees and costs while FCF claims are progressed
  • Change PPF compensation provisions with regard to surviving child dependants so that a gap between qualifying courses of more than one year does not result in the loss of PPF compensation

In its response to the consultation, the DWP said that the Government will proceed with the above two regulatory amendments, having made one minor change to their wording in relation to the FCF amendment.

The Occupational Pension Schemes (Pension Protection Fund (Compensation) and Fraud Compensation Payments) (Amendment) Regulations 2023 (SI 2023/265) come into force on 6 April 2023.

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