The Pensions Regulator (TPR) has faced calls to provide further explanation of intent around some key areas in its draft pension dashboards compliance and enforcement policy, with particular concerns raised around data requirements.

Responding to TPR's consultation, the Pensions and Lifetime Savings Association (PLSA) welcomed the regulator's pragmatic approach, stating that it is "clear" that TPR wishes for the measures to be workable in the face of the "well-understood challenges" that will be encountered by schemes as part of the dashboards process.

However, the PLSA raised concerns as to how the regulations will be enforced in more complex circumstances with potential issues that could arise as schemes begin to connect, querying how TPR intends to enforce compliance beyond the limited scenarios provided thus far.

It stated: "While the scenarios provided do indicate how TPR intends to investigate certain breaches of compliance, we feel there could be some more clarity on how it would investigate more nuanced and complex cases.

"PLSA members have expressed that they would be happy to provide TPR with some examples of additional scenarios, if required."

For instance, the PLSA noted that, in practice, schemes will only face teething issues with, for instance, matching policies, during testing, by which point they will be bound by the regulations.

In light of this, it argued that pension schemes need reassurance that they will not be penalised for issues that only become apparent once they start to match data.

The PLSA also raised broader concerns around data matching requirements, however, suggesting that pension schemes would welcome further engagement on this as there are several matters still unresolved.

In particular, the PLSA suggested that pension schemes would benefit from knowing where the regulator plans to set the bar in terms of data quality, pointing out that schemes, particular large master trusts, have limited control over the ongoing accuracy of personal data items.

The PLSA also encouraged TPR to adopt a "highly pragmatic and supportive approach to its compliance and enforcement powers on schemes".

PLSA director of policy and advocacy, Nigel Peaple, stated: “We welcome the overall pragmatic approach taken in the draft policy.

"It is clear that TPR wishes for the compliance and enforcement measures to be workable in the face of the well-understood challenges that will be encountered during the staging process.

“There remain some areas where further explanation of intent is required. These areas relate to how the regulations will be enforced in complex circumstances with potential issues that could arise as schemes begin to connect.

"Ideally, TPR would also provide clarity over acceptable matching rates during the testing and launch, as well as where the bar will be set with regard to data quality as certain data inaccuracies will be beyond schemes’ control.

“The pragmatic approach taken by the regulator is essential to securing an outcome that delivers a strong framework of compliance and enforcement, whilst also ensuring schemes can practically deliver on what is required of them.”

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