Pensions dashboards – staged connection timetable published

The government has published statutory guidance setting out the staged timetable for connection to the pensions dashboards ecosystem. Although the statutory deadline for connection is 31 October 2026, schemes are required to have regard to this guidance in complying with their duty to connect i.e. schemes are encouraged to connect by the relevant date set out in the guidance unless there are exceptional circumstances which prevent them from doing so. The Pensions Regulator (TPR) has provided further guidance on trustees’ obligations to have regard to the statutory guidance.

The timetable is based on scheme size and type. It will start with the largest DC schemes which will be encouraged to connect by 30 April 2025. A scheme’s size for the purposes of the timetable will be determined by the number of “relevant” members as at the “reference date”. Relevant members include active, deferred and pension credit members (but not pensioners). The reference date is the scheme year end date falling between 1 April 2023 and 31 March 2024. TPR has produced a tool to help schemes establish their staged connection date.

What should trustees be doing?

Trustees should establish their scheme’s staged connection date under the statutory guidance. If there are any circumstances which they believe may prevent or delay the scheme from connecting by that date, trustees should consider this carefully in light of the guidance.

How can Mayer Brown help?

We can assist trustees by advising on their staged connection date under the timetable, advising on circumstances which may prevent/delay connection, and advising more generally on compliance with their duties having regard to the statutory guidance.

We can also assist trustees with compliance with their duties under the pensions dashboards legislation more broadly, including:

• Providing training on those duties.
• Advising on service provider contracts and/or changes to service provider contracts.
• Advising on data protection obligations.