DAP notice period extended to six months

The Department for Work and Pensions (DWP) has announced plans to extend the notice period for the pensions dashboards available point from 90 days, as initially proposed, to at least six months.

The regulations have been laid in parliament today (17 October 2022), with DWP confirming that it intends to lay the Amending Order "as soon as parliamentary time allows" once the regulations have been approved.

Industry experts previously warned that the proposed 90-day window was too short, with some suggesting that a phased approach may instead be better, considering scheme resources.

In its response to the consultation, the DWP acknowledged that the 90-day formal notice period could create challenges for the organisations that need to prepare for this, stating that it has "conscientiously considered" industry responses.

The extended six-month notice period is therefore expected to provide greater certainty for the pensions industry to make final preparations for the public launch of pensions dashboard services.

However, although the DWP acknowledged calls for multiple DAPs to help reduce resource requirements on schemes, it argued that the six-month DAP notice period should provide the industry with "sufficient time" to prepare for a single DAP.

It also suggested that multiple DAPs could be confusing both in terms of user experience and ensuring consumer communication campaigns are clear and effective.

However, the DWP emphasised that the government remains committed to working transparently with industry about when the formal notice of the DAP will be issued, confirming that it expects to publish any progress towards DAP to ensure the industry is aware of when the likely date for the DAP will be.

In addition to this, the department will continue to engage with key delivery partners on the decision of when to specify the DAP.

Based on the initial consultation feedback, the DWP has also outlined a broad framework to help inform the Secretary of State when deciding whether the dashboards ecosystem is ready to support widespread use, identifying four key areas of consideration: sufficient coverage, dashboards effectiveness, safety and scrutiny and user experience.

The DWP said it expects the matters to support the Secretary of State in determining the date of the DAP to be in place by April 2023, coinciding with when the first connection window opens for schemes to begin connecting on a compulsory basis.

More broadly, the DWP confirmed that it is proceeding with its proposals on the disclosure of information provision as planned, to enable The Pensions Regulator (TPR) and the Money and Pensions Service (MaPS) to support each other as appropriate in their roles relating to the secure delivery of the pensions dashboards digital architecture.

Commenting on the changes, LCP partner, Steve Webb, said: “The decision to give pensions schemes and providers more notice before pensions dashboards go live to the public is very sensible.

"The previous proposal of just three months’ notice would have given schemes very little time to put in place the capacity they will need if there is an early surge in engagement with dashboards.

"Even six months will be challenging but it is a welcome sign that the department has listened to the practical issues being raised by the industry”.

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