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COBS 19.11 Pensions dashboards

Who?

COBS 19.11.1R

1This section applies to an operator of a relevant pension scheme. For the avoidance of doubt, in this section, a personal pension scheme includes a personal pension product and therefore the provider of a personal pension product is within the scope of the rules in this section.

Purpose

COBS 19.11.2G

The purpose of this section is to ensure that an operator of a relevant pension scheme provides and facilitates the provision of sufficient pensions dashboard view data to a pensions dashboard service.

COBS 19.11.3G

This section specifies the requirements placed on an operator of a relevant pension scheme to:

  1. (1)

    register with the Money and Pensions Service;

  2. (2)

    connect with the MaPS dashboards digital architecture;

  3. (3)

    provide and facilitate the provision of sufficient information in response to pensions dashboard find requests and pensions dashboard view requests; and

  4. (4)

    comply with pensions dashboard standards and have regard to pensions dashboard guidance as appropriate.

COBS 19.11.4G

Where a firm is required by the rules in this section to have regard to pensions dashboard guidance, the firm will need to do so with due skill, care and diligence (in line with Principle 2). Firms will need to be able to demonstrate that they have taken into account the relevant guidance and the intended outcomes when considering whether their own systems are in line with that guidance and comply with the rules in this section.

Co-operation with, and notifications to, the Money and Pensions Service

COBS 19.11.5R

A firm must:

  1. (1)

    cooperate with the Money and Pensions Service as far as is reasonably necessary to assist with the exercise of the Money and Pensions Service’s functions in relation to pensions dashboard services; and

  2. (2)

    comply with the service and operational pensions dashboard standards.

COBS 19.11.6R

In compliance with the service and operational pensions dashboard standards, a firm must notify the Money and Pensions Service as soon as possible once it becomes aware of any of the following issues:

  1. (1)

    connection state changes, such as scheduled downtime or maintenance;

  2. (2)

    systemic issues, such as cyber-attacks that could affect the security of the MaPS pensions dashboards ecosystem; and

  3. (3)

    changes in connection arrangements.

COBS 19.11.7R

A firm must immediately notify the Money and Pensions Service if it is disconnected from the MaPS dashboards digital architecture.

Registration and connection to the Money and Pensions Service

COBS 19.11.8R

A firm must:

  1. (1)

    register with the Money and Pensions Service having regard to pensions dashboard guidance relating to connection;

  2. (2)

    ensure that it is, and remains, connected to the MaPS dashboards digital architecture:

    1. (a)

      in compliance with the pensions dashboard standards relating to:

      1. (i)

        connection and security standards;

      2. (ii)

        technical standards; and

    2. (b)

      having carried out the steps in the pensions dashboard guidance relating to connection or any alternative steps the firm has taken to achieve the same result; and

  3. (3)

    make and maintain a record of how it has complied with (2)(b) for at least 6 years from the end of the calendar year to which the information relates.

Responding to find requests and the matching process

COBS 19.11.9R

A firm must determine the pensions dashboard matching criteria to use for the pensions dashboard matching process:

  1. (1)

    having regard to pensions dashboard guidance on matching; and

  2. (2)

    taking into account:

    1. (a)

      the nature and quality of the pensions dashboard find data held by the firm; and

    2. (b)

      the firm’s preferred approach to preventing data breaches.

COBS 19.11.10R

A firm must make and maintain a record of the pensions dashboard matching criteria determined by the firm in COBS 19.11.9R for at least 6 years from the end of the calendar year to which the information relates.

COBS 19.11.11R

On receipt of a pensions dashboard find request, a firm must immediately follow the pensions dashboard matching process having regard to pensions dashboard guidance on matching.

COBS 19.11.12R

Where there is a positive match relating to a pensions dashboard user who is or could be a relevant pension scheme member, a firm must:

  1. (1)

    immediately create a pension identifier;

  2. (2)

    register the pension identifier with the Money and Pensions Service in accordance with technical pensions dashboard standards; and

  3. (3)

    store information that indicates whether the pension identifier relates to a match made or a possible match.

COBS 19.11.13R

Where there is a possible match, a firm must:

  1. (1)

    check with the Money and Pensions Service that the pensions dashboard user to whom the pensions dashboard find request relates has consented to their pensions dashboards view data being provided to the pensions dashboard service that issued the pensions dashboard view request;

  2. (2)

    if the Money and Pensions Service confirms the information in (1), immediately provide the limited form of administrative data to the pensions dashboard service that issued the pensions dashboard view request:

    1. (a)

      in the format and manner set out in the pensions dashboard standards on data; and

    2. (b)

      having regard to pensions dashboard guidance on data;

  3. (3)

    immediately send a message, in accordance with the pensions dashboard standards on data, to the pensions dashboard service that issued the pensions dashboard view request, indicating that:

    1. (a)

      further information is required in order to determine if the pensions dashboard user is a relevant pension scheme member; and

    2. (b)

      the pensions dashboard user to whom the pensions dashboard find request relates must contact the operator of the relevant pension scheme to which the possible match relates, within 30 days of receiving the limited form of administrative data, to provide further information so that the relevant pension scheme can determine whether the pensions dashboard user is a relevant pension scheme member;

  4. (4)

    if the pensions dashboard user to whom the pensions dashboard find request relates contacts them, immediately seek to resolve the possible match having regard to the pensions dashboard guidance on matching;

  5. (5)

    where the pensions dashboard user to whom the pensions dashboard find request relates:

    1. (a)

      does not make contact with the operator of the relevant pension scheme regarding the possible match within 30 days of receiving the limited form of administrative data; or

    2. (b)

      does make contact, but the relevant pension scheme, having regard to pensions dashboard guidance on matching, is unable to resolve the possible match as a match made within such time as may be reasonably allowed by the relevant pension scheme,

    the firm must delete the pensions dashboard find request and de-register the pension identifier from the Money and Pensions Service as soon as possible; and

  6. (6)

    notify the Money and Pensions Service if the relevant pension scheme determines subsequently that the pensions dashboard user is a relevant pension scheme member.

COBS 19.11.14R

Where a positive match or a possible match is made but the relevant pension scheme member subsequently ceases to be a relevant pension scheme member, the firm must de-register the pensions identifier from the Money and Pensions Service as soon as possible.

Responding to view requests and requirement to provide view data

COBS 19.11.15R

Where there is a match made (including where a possible match subsequently results in a match made) and the firm receives a pension dashboard view request, a firm must:

  1. (1)

    check with the Money and Pensions Service that the relevant pension scheme member to whom the pension dashboard find request relates has consented to their pensions dashboard view data being provided to the pensions dashboard service that issued the pension dashboard view request;

  2. (2)

    if the Money and Pensions Service confirms the information in (1), provide the relevant pension scheme member’s pensions dashboard view data to the pensions dashboard service that issued the pensions dashboard view request; and

  3. (3)

    ensure the pensions dashboard view data:

    1. (a)

      is in the format and manner set out in the pensions dashboard standards on data; and

    2. (b)

      is provided having regard to the pensions dashboard guidance on data.

Administrative data – timescales

COBS 19.11.16R

A firm must provide the administrative data element of pensions dashboard view data required to be provided in COBS 19.11.15R(2), in accordance with the following timescales:

  1. (a)

    if the pensions dashboard view request relates to a relevant pension scheme member who has joined the relevant pension scheme less than 3 months ago:

    1. (i)

      as soon as practicable; and

    2. (ii)

      in any event, no later than 3 months after the relevant pension scheme member’s joining date.

  2. (b)

    in any other case, immediately after the request is received by the firm.

Administrative data – content

COBS 19.11.17R

The administrative data element of pensions dashboard view data required to be given in COBS 19.11.15R(2) must be provided:

  1. (1)

    in accordance with the pensions dashboard standards on data; and

  2. (2)

    having regard to pensions dashboard guidance on data.

COBS 19.11.18R

The administrative data is comprised of the following:

  1. (1)

    the date of birth of the relevant pension scheme member concerned;

  2. (2)

    information about the relevant pension scheme;

  3. (3)

    information about the administrator of the relevant pension scheme; and

  4. (4)

    where applicable and to the extent available, information about the employment that gave rise to the accrual of the pension saving.

COBS 19.11.19R

The information about the relevant pension scheme referred to in COBS 19.11.18R(2) must include:

  1. (1)

    the name of the relevant pension scheme;

  2. (2)

    a description of the types of benefit provided under the relevant pension scheme to the relevant pension scheme member;

  3. (3)

    whether the relevant pension scheme member is an active pension scheme member or a deferred pension scheme member or a pension credit member; and

  4. (4)

    the date when the relevant pension scheme member became a member of the relevant pension scheme.

COBS 19.11.20R

The information referred to in COBS 19.11.18R(3) about the administrator of the relevant pension scheme must include:

  1. (1)

    the name of the administrator having regard to pensions dashboard standards on data;

  2. (2)

    information to enable the relevant pension scheme member to get in touch with the administrator, which complies with pensions dashboard standards on data and which includes at least one of the following:

    1. (a)

      the administrator’s website address;

    2. (b)

      the administrator’s email address;

    3. (c)

      the administrator’s telephone number and telephone number type, including whether the number is the primary telephone number, is appropriate for Welsh language speakers, or is for text message service only; and

    4. (d)

      the name and full postal address of the administrator.

COBS 19.11.21R

The information referred to in COBS 19.11.18R(4) about the employment to which the pension saving in the relevant pension scheme relates must (where applicable and to the extent available) include:

  1. (1)

    the start date of the earliest period of employment which generated the accrual of the pension saving;

  2. (2)

    in relation to a deferred member, the end date of the latest period of employment which generated the accrual of the pension saving;

  3. (3)

    in a case where the employment which generated the accrual of the pension saving relates to a single employer, the name of the employer;

  4. (4)

    in a case where the employment which generated the accrual of the pension saving relates to more than one employer, whichever of the following is most appropriate:

    1. (a)

      the name of the most recent employer; or

    2. (b)

      confirmation that there have been multiple employers.

Signpost data – timescales and location

COBS 19.11.22 R

To the extent that signpost data is applicable to the nature of the relevant pension scheme or the type of benefit in question, where a firm has to provide pensions dashboard view data under COBS 19.11.15R(2), a firm must provide the signpost data element (or where relevant, the data in (3)):

  1. (1)

    immediately; and

  2. (2)

    by providing a website address for locations where signpost data can be accessed by the relevant pension scheme member to whom the pensions dashboard view request relates.

  3. (3)

    Where a firm does not already have information on member-borne costs and charges available on a website, the firm must instead provide clear information to the relevant pension scheme member on the website referred in (2) about how they can obtain details about their member-borne costs and charges.

Requirement to provide value data

COBS 19.11.23R

A firm must provide the value data element of the pension dashboard view data in accordance with COBS 19 Annex 6 in respect of a relevant pension scheme member, unless an exemption set out below applies.

COBS 19.11.24R

A firm is not required to provide the projected pension pot value or the annualised projected pension value under COBS 19 Annex 6 1R in respect of a relevant pension scheme member:

  1. (1)

    with money purchase benefits; or

  2. (2)

    with hybrid benefits where the benefit is calculated with reference to both money purchase benefits and benefits other than money purchase benefits (if any),

where all of the following criteria are met in relation to the relevant pension scheme member:

  1. (3)

    the value of the relevant pension scheme member’s accrued rights to money-purchase benefits under the relevant pension scheme, determined in accordance with the relevant pension guidance, was less than £5,000 on the last illustration date;

  2. (4)

    since the previous illustration date, no contributions (including transfers of pension rights and pension credits) have been made to the relevant pension scheme by, or on behalf of, the relevant pension scheme member in respect of their money-purchase benefits; and

  3. (5)

    the firm has previously given notice to the relevant pension scheme member that a pension illustration will not be given to them again unless further contributions referred to in (4) have been made.

COBS 19.11.25R

A firm is not required to provide a projected pension pot value or an annualised projected pension value under COBS 19 Annex 6 1R in respect of a relevant pension scheme member:

  1. (1)

    with money purchase benefits; or

  2. (2)

    with hybrid benefits where the benefit is calculated with reference to both money purchase benefits and benefits other than money purchase benefits; and

who is within 2 years of their retirement date.

COBS 19.11.26G

A firm may provide the projected pension pot value or the annualised projected pension value in respect of a relevant pension scheme member where, under COBS 19.11.24R, or COBS 19.11.25R the firm is not required to do so.

COBS 19.11.27R

A firm is not required to provide an annualised projected pension value or an annualised accrued pension value under COBS 19 Annex 6 3R if the cash balance benefit was established in such a way that it was designed to provide a lump sum on retirement.

Value data – timescales

COBS 19.11.28R

Where a firm is required to provide pension dashboard view data under COBS 19.11.15R(2), it must provide the value data immediately after the pensions dashboard view request is received, unless the situations set out in COBS 19.11.29R or COBS 19.11.30R apply, in which case the timescales set out in those rules apply.

COBS 19.11.29R

Where the value data has not been generated for a pension benefits statement provided to the relevant pension scheme member within the past 13 months, or is not based on a calculation that was made using the same methodology as would have been used for such a pension benefits statement made within the past 12 months, the following timescales apply:

  1. (1)

    where all of the benefits provided to a relevant pension scheme member are money purchase benefits, the value data must be provided within 3 working days from the day after the date on which:

    1. (a)

      a pension identifier is registered for a match made; or

    2. (b)

      (if relevant) the Money and Pensions Service is notified that a possible match is a match made;

  2. (2)

    in all other cases (including where the benefits provided to a member are hybrid benefits which depend on anything other than a money purchase benefits calculation), the value data must be provided within 10 working days from the day after the date on which:

    1. (a)

      a pension identifier is registered for a match made; or

    2. (b)

      (if relevant) the Money and Pensions Service is notified that a possible match is a match made.

COBS 19.11.30R

Where a pensions dashboard view request is issued by a pensions dashboard service in respect of a relevant pension scheme member within 12 months of the end of that member’s first full calendar year, the firm must meet the requirements of COBS 19.11.23R, COBS 19.11.29R, COBS 19.11.32R and COBS 19.11.33R as soon as practicable, and no later than the sooner of:

  1. (1)

    the point at which the first pension benefits statement has been produced for the relevant pension scheme member; or

  2. (2)

    12 months after the end of the relevant pension scheme member’s first full calendar year.

COBS 19.11.31R

Where an element of value data that a firm is required to provide is not returned on time:

  1. (1)

    the firm must provide a reason for the delay (in particular if there is a system error or a delay in calculation), in accordance with pensions dashboard standards relating to data; and

  2. (2)

    the giving of a reason under (1) does not excuse the firm from the requirement to provide the element of value data.

Value data – illustration date and contextual information

COBS 19.11.32R

The value data must:

  1. (1)

    be from:

    1. (a)

      a pension benefits statement provided to the relevant pension scheme member within the last 13 months, even if the values in that pension benefits statement were calculated more than 13 months ago, and whether or not such a calculation was done in response to an earlier pensions dashboard view request; or

    2. (b)

      a calculation performed for the relevant pension scheme member within the last 12 months, whether or not such a calculation was done in response to an earlier pensions dashboard view request; and

  2. (2)

    have the same illustration date.

Contextual information

COBS 19.11.33R

A firm must provide the following contextual information to the extent relevant in the circumstances:

  1. (1)

    the illustration date, having regard to pensions dashboard guidance relating to value data;

  2. (2)

    whether the value is expressed as an annual income, lump sum or as a pot value;

  3. (3)

    whether the value displayed contains any safeguarded benefits;

  4. (4)

    whether the value displayed includes any spouse’s or civil partner’s or dependant’s benefits; and

  5. (5)

    whether the benefits, once in payment, could be subject to change;

  6. (6)

    the type of illustration provided, as referred to in the pensions dashboard standards on data;

  7. (7)

    the date from when a benefit is to be payable or, where benefits are to be paid in tranches, the date from when each tranche of benefit is to be payable;

  8. (8)

    if a pension benefit is payable for a fixed term, the date that the benefit is payable to (although benefits payable until death should leave the ‘to’ date blank);

  9. (9)

    additional information to help the relevant pension scheme member better understand their value data, including whether:

    1. (a)

      the benefits are hybrid pension benefits;

    2. (b)

      the pension may increase or decrease in payment;

    3. (c)

      the pension may stop paying out or reduce at a certain age;

    4. (d)

      if there are multiple tranches of benefits, more than one retirement date has been used to calculate the value;

    5. (e)

      the relevant pension scheme member should get in touch with the operator of the relevant pension scheme regarding the value displayed, together with the reason for getting in touch; and

    6. (f)

      a calculation method has been used as referred to in COBS 19 Annex 6 2.2(2).

  10. (10)

    For (2), (3), (4), (5), (8) and (9), the data element in each case should be selected from a fixed list, as set in the pensions dashboard standards on data.

Operational information and reporting

COBS 19.11.34R

A firm must be in a position to provide operational information:

  1. (a)

    to the FCA when requested to do so by the FCA; or

  2. (b)

    to the Money and Pensions Service when requested to do so by the Money and Pensions Service, in accordance with pensions dashboard standards relating to reporting.

COBS 19.11.35R

The operational information which may be requested by the FCA includes, but is not limited to, information on the following:

  1. (1)

    the number of pensions dashboard find requests received by the firm;

  2. (2)

    the pensions dashboard matching process used by the firm;

  3. (3)

    in relation to positive matches:

    1. (a)

      the number of matches made that are notified to the Money and Pensions Service; and

    2. (b)

      how quickly any uncertainties in relation to possible matches were resolved;

  4. (4)

    in relation to possible matches:

    1. (a)

      the number of possible matches that are notified to the Money and Pensions Service; and

    2. (b)

      how many of these resulted in a match made, resulted in no match being made, or remained unresolved;

  5. (5)

    the number of pensions dashboard view requests received by the firm and the time taken to respond to each one;

  6. (6)

    contacts received from users, including details of:

    1. (a)

      queries about pensions information provided;

    2. (b)

      pensions not found following a search; and

    3. (c)

      complaints; and

  7. (7)

    any aspect of the data processing of a pensions dashboard user’s request for pensions information.

COBS 19.11.36G

The operational information which may be requested by the Money and Pensions Service includes, but is not limited to, information set out in COBS 19.11.35R. Failure to comply with a request by the FCA or Money and Pensions Service is likely to be considered a breach of FCA Principle 11 or COBS 19.11.5R and in significant cases might be considered a breach of the threshold conditions.

COBS 19.11.37R

A firm must make, and maintain for 6 years from the end of the calendar year to which it relates, a record of the operational information specified in COBS 19.11.35R.

Record keeping

COBS 19.11.38G

The rules in this section regarding record keeping are in addition to any other record-keeping requirements to which the firm is subject.