Plan

DRAFT FOR DISCUSSION BY INTERESTED PARTIES

This page outlines a possible plan for discussing, agreeing and launching PDOC during 2024, and initial ideas for PDOC’s immediate workplan.


The legislation is here

DWP made Pensions Dashboards Regulations in December 2022 and HMT’s draft legislation which builds on this to make “Operating a pensions dashboard service” a new FCA-regulated activity comes into force in just a few weeks on 11 March 2024:

So now is the time to think about setting up a group of dashboard providers: the Pensions Dashboard Operators Coalition (PDOC).


Possible plan

What steps are required during 2024 to discuss, agree and launch PDOC?:

February 2024 – Socialisation

  • Socialisation: Socialise the PDOC concept with interested parties within industry, Government and Regulators
  • Inaugural members: Determine which organisations wish to be the initial “founding” members of PDOC (see Membership for ideas)

March 2024 – Announcement “in principle”?

  • Announcement preparations: Prepare announcement communications and obtain approval by all initial PDOC members
  • Notifying Government: Notify DWP, MaPS, PDP, FCA that PDOC is being announced “in principle” and agree supportive communications as appropriate
  • Draft website refinement: Refine this website (pdoc.org.uk) to reflect the above
  • Public announcement (second half of March, once the Regulated Activities (Order) amendment is in force?): Announce that a new coalition of dashboard providers is being created “in principle”, with a 6-month setup phase from Apr to Oct 2024

April to October 2024 – Setup phase

  • Constitution: Determine how PDOC should be formally constituted and structured and agree governance arrangements (see Structure for ideas)
  • Code of Conduct: Develop and agree PDOC Code of Conduct
  • Collateral: Agree how PDOC collateral will be developed and published
  • Funding: Determine the funding PDOC needs and agree appropriate funding sources
  • Members: Discuss and agree PDOC membership terms (see Membership for ideas)
  • Workplan: Discuss immediate, mid- and long-term workplans for PDOC
  • Launch preparations: Prepare to formally launch PDOC in October 2024*
  • Launch: Publish launch communications and respond to media enquiries

* Aligned as appropriate with both a) the pre-election period of sensitivity (‘purdah’), and b) the Autumn conference season (such as the PLSA Annual Conference on 15-17 Oct 2024).


Initial ideas for immediate PDOC Workplan

Once PDOC is launched, what should its immediate priorities be?:

  • Planning live user testing: PDOC should play a full and active role in the new PDP User Testing and Planning Group (UT&PG) as soon as it is established
  • Developing dashboards connection guidance: PDP has said it will produce guidance with “additional information about the route to become a pensions dashboard service” – this guidance should be developed collaboratively between PDOC and the new PDP Dashboards Connection Working Group later in 2024
  • Defining QPDS pre-connection audit scope: PDOC should convene discussions with nascent QPDS audit firms, together with Government and Regulators, to help define the scope of statutory pre-connection QPDS audits (to enable firms to apply to FCA for PDS permissions once the FCA opens the Authorisation Gateway)


Looking ahead to 2025 and beyond

For a dashboard operator which is a member of PDOC, priorities during 2024 and going into 2025 will be (* = with PDOC):

  • preparing their QPDS application to FCA
  • appointing an auditor
  • undergoing a statutory pre-connection audit
  • submitting their application to FCA
  • supporting the planning of user testing*
  • supporting the development of dashboards connection guidance*
  • potentially receiving QPDS permissions from FCA
  • potentially connecting their QPDS to the CDA.


Looking further forward into 2025 and beyond, a PDOC member’s priorities will be:

  • receiving QPDS permissions from FCA
  • connecting their QPDS to the CDA
  • executing user testing*
  • feeding back results from user testing*
  • feeding back on the Step 2 CDA interface*
  • supporting progress towards the DAP notice*
  • preparing for their QPDS launch from the DAP
  • undergoing statutory annual QPDS audits
  • optimising their QPDS following the DAP
  • supporting iteration of QPDS Rules & Standards*.


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