The lack of test dashboards has made it “near impossible” for the pensions industry to feedback on dashboards’ design proposals, the Pensions and Administration Standards Association (Pasa) has said, arguing that "very extensive" user testing is needed.

In a joint response to the Pensions Dashboard Programme (PDP) and the Financial Conduct Authority (FCA) pension dashboard consultations, Pasa argued that there is a “fundamental challenge in the way the dashboards initiative is being played out”.

In particular, the association explained that whilst it had been suggested that there would be the opportunity for interested organisations to create and test dashboards, this approach “hasn’t been followed in practice”.

“The Money and Pensions Service (Maps) MoneyHelper dashboard team has done some wireframe testing of mock dashboard designs," it continued. "But the detailed outcome of this isn’t in the public domain and so hasn’t been able to inform our responses to these consultations.”

In addition to this, Pasa raised concerns that because of the way the regulatory framework has developed, the first Qualifying Pensions Dashboard Service (QPDS) won’t be authorised by FCA, and connected to the PDP central digital architecture (CDA) to begin end-to-end testing with real pensions data, until "at least Christmas 2023".

"We’re aware the Maps MoneyHelper dashboard is connected to the CDA, but this team’s testing plans, particularly the testing of different data variances, are unclear to us," Pasa said.

"It also isn’t clear how the Maps MoneyHelper dashboard plans align with PDP’s separate plans."

In light of this, Pasa urged the FCA to authorise the first PDS applicants "as soon as possible", to ensure they can connect to the PDP CDA and detailed testing can commence from "very late 2023/early 2024".

Indeed, Pasa argued that "very extensive testing with individuals with wide variances of pensions data will be necessary to discover what displays work best for them", suggesting that this may need to be at least 12 to 24 months of testing from the point the first cohort of schemes are connected.

Pasa also encouraged "all parties" involved in developing pensions dashboards to recognise that the design standards will "almost certainly need to change after testing", suggesting that the first opportunity to announce changes will likely be October 2024.

If announced in October 2024, Pasa predicted that these changes could come into force in October 2025.

However, it suggested that a further period of testing will be required after this to ensure the revised standards are operating as anticipated, predicting that a "realistic scenario" could place the dashboards available point in Spring 2026.

More broadly, the association argued that there is not sufficient recognition of the amount of configuration work required by schemes, particularly in relation to making DB schemes data available and the potential challenges this may present to administrators. .

In addition to this, the response raised concerns over the potential impact on administrators after savers see their pensions dashboards, explaining that any ambiguity arising from the information supplied on a dashboard, or user queries over the way information is presented, will likely be referred to the pension scheme administrator.

In light of these concerns, Pasa emphasised the need to "protect day-to-day service", warning that this could be "seriously impacted" if dashboards give rise to a larger number of queries than necessary.

Pasa chair, Kim Gubler, stated: “PASA set up its Pensions Dashboards Working Group (PDWG) in March 2017 and has been considering these issues in depth since this time.

“As a number of our comments are thematic across several questions, we’re submitting this combined document of all our responses on both consultations. We’ve focused on the topics with most material impact on pensions administration.”

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