ABI response to further consultation on the regulatory framework for pensions dashboard service firms
Following on from its initial consultation CP22/25, concluding in February 2023, the FCA has sought further feedback from the industry via a second consultation on the regulatory framework for commercial dashboards.
As part of the consultation, the regulator has sought views on its Perimeter Guidance, which aims to help firms understand the scope of its regulation. The FCA has also proposed changes to the framework which include requirements for the choice architecture of commercial dashboards to include standardised wording, along with exit communications for users wanting to redirect to a different website or page.
In response to these proposals
We welcome the FCA’s plans to clarify the scope of their activity for firms interested in operating a pensions dashboard service. This much-needed clarity will help to guide firms seeking to outsource elements of their dashboards function to companies outside of the regulator’s remit. We’re also pleased to see that the proposed regulated activity will cover multiple pensions dashboards. By allowing multiple dashboards there will be room to innovate to meet different customers’ needs, and an increased reach means more users will benefit from dashboards.
As we work towards delivering this vital service, it is important we do so with the user front of mind. Dashboards must be easy to interact with so that customers feel empowered to make informed decisions. The proposed changes to the choice architecture of commercial dashboards risk making the customer journey complex and challenging. The amount of information, warnings and restrictions the FCA would like to implement, could be confusing and is more likely to put the customer off making decisions altogether – risking the benefits that dashboards are designed to deliver. We would like to see the FCA and PDP map out and test the end-to-end customer journey with their proposed changes to ensure that customers understand them and to check whether they add value.
The industry continues to strongly support the pensions dashboards initiative, which has potential to be transformational in increasing customer engagement with pensions - ultimately leading to better customer outcomes. We look forward to continuing our work with the industry, government and the Pensions Dashboard Programme on delivering this important service, ensuring that comprehensive, effective dashboards can be delivered as soon as possible.
Our response to the consultation is available here.
For more information please contact ABI Press Office.
