Besides potential enforcement action, Smith says there is a regulatory communication strategy and programme in place.
“The regulator has already contacted us, to tell us that they will be in touch with the nominated person with the actual [‘connect by’] date – we know our date is April anyway – but with more detail to come.
“And there will be quite a constant drumbeat of communication, as far as I understand, to make sure that schemes do take notice, and they do start getting their house in order, their data ready.”
While many who are not involved in the dashboard programme may be sceptical, Paul Waters, head of DC markets at Hymans Robertson, likewise says there is far more positivity and optimism about the delivery of the programme in line with the latest timescales, for those who are working more closely with it.
“Our pensions administration business is connecting our data to the dashboard. And through the work we're doing with financial services providers, the way that this has moved on, with the Pensions Administration Standards Association’s guidance, the connection information, the testing, the infrastructure, it's miles ahead of the old experience people have had of ‘dashboards are delayed, dashboards are delayed’.
“We've done masses and masses of the hard work on data plumbing, testing, governance rules, protocols.”
Although there is optimism about the progress of dashboards, it may perhaps be ambitious to expect too much, too soon.
“The DWP guidance and FCA consultation bring us closer to the reality of dashboards being live for UK savers,” says Waters. “It feels like we are getting there, and it’s more ‘two steps forward and one step back’ than the early days of the programme when the opposite could be said.
“The ‘one step back’ part refers to the lack of clarity and clear guidance on the post-view services providers can offer to give the consumers the ‘so what’ that is needed after seeing their dashboard data,” he adds.
“The FCA notes that this will be linked to the outcome of the advice guidance boundary review. The result needs to be a permissive regime to help consumers understand their options and take action on using the dashboard, controlled under the protection of the consumer duty.
“Without this, dashboards could feel a bit like we’ve made a huge investment to build a motorway, and then put a 20mph speed limit on it.”
As Smith also highlights, the dashboards that are slated to launch will be their first iteration.
