I talk to Chris Curry about what the dashboard tells us about UK pensions infrastructure
Pensions Goth: I want to explore the problems with data sharing in UK pensions, particularly the absence of a reliable identification number and wider gaps in data infrastructure. How has the dashboard programme dealt with these issues, and what still needs to be fixed?
Chris Curry: Two long-standing problems have shaped the dashboard programme: poor data quality across pension schemes, and the absence of a single digital identifier for individuals. On identification, most countries that have built pension dashboards already have a single digital identifier for citizens, which makes it straightforward to link a person to their pensions across different providers. The UK does not have this. On data quality, older schemes often lose touch with members who stop contributing and have no reason to update their record until they retire. Automatic enrolment schemes are more modern but face a different problem: people change jobs frequently, which means they move between pension providers and records become fragmented. Regulation has not resolved either issue. Schemes must report their data quality to regulators, but without a visible problem it has been difficult to act proactively.
Pensions Goth: Has the dashboard programme helped address any of this?
Chris Curry: To a degree, yes. To make matching people to their pensions possible, we developed data standards, first published in January 2021, which every qualifying scheme must follow. These set out how personal information such as name, date of birth, national insurance number, and address must be returned to the dashboard. That kind of consistency simply did not exist across the industry before. The standards were developed with input from industry to balance what is needed for matching against what providers can realistically do. The Government has also required schemes to carry out regular benefit calculations, which was not happening consistently in parts of the defined benefit world. These improvements will benefit other policy areas too, including pension transfers and small pot consolidation, even though the dashboard itself does not move money.
Pensions Goth: What has industry said about the cost of complying with the new standards?
Chris Curry: Industry has been vocal about the additional work involved, which is understandable. But much of what providers have had to do is work that probably should have been done years ago. The dashboard has acted as a catalyst, pushing data quality up the priority list in a way that other policy pressures had not managed. PASA has published guidance on matching that many providers are using. PPI testing, carried out with Nest, Legal and General, and Smart, found that combining a national insurance number with name and date of birth produces reliable matches, particularly for automatic enrolment records. The national insurance number is not compulsory on the dashboard in part because it cannot be verified through GOV.UK One Login, meaning a user could enter the wrong number without the system knowing, and also because not every individual knows their NI number. To improve this, we have worked hard to encourage users to provide it, and the dashboard includes a link to a government service where people can look up their number if they do not know it.
Pensions Goth: Is there a case for introducing a new, more reliable identifier rather than relying on the national insurance number?
Chris Curry: I do not think it is practical. There are already around 60 to 80 million pension records in the system that would not carry any new identifier. You would still need to match those existing records using conventional methods before you could attach a new identifier to them, so you have not actually solved the problem. It would also place a significant new burden on industry, which runs counter to our approach of only asking providers for information they already hold. GOV.UK One Login, already used by DVLA, and due to be adopted by HMRC and DWP, offers a better route: a single cross-government identity that people can use across public services, not just pensions. Matching will also improve over time as more people use the dashboard. When someone gets a possible match, they contact their provider to correct the record, which means data quality gradually improves through use.
Pensions Goth: Will better data quality make pension transfers faster and cheaper?
Chris Curry: It should make it easier to match a person to their pension pots, but whether that makes the transfer process itself faster or cheaper is less certain. Data matching may not be the main bottleneck in transfers. There are also consumer protection issues to consider: people need to understand what they are doing when they transfer, including how charges and investment returns affect their pension over time. Once the Pension Schemes Act is implemented, there is potential for the dashboard to connect with the value for money framework, which could help members make better-informed decisions about whether to consolidate their pensions.
Pensions Goth: What about the ability to action a transfer directly through the dashboard, as exists in Australia?
Chris Curry: That is a long way off, if it ever becomes appropriate here. The Australian system is less fragmented than the UK’s, more mature, and has a value for money framework that has been actively reducing the number of providers over time. In the UK, consolidation is currently happening at scheme level rather than at the level of individual members, and much of it takes place outside workplace schemes, which is a different structure. The dashboard will evolve, but the direction will depend on how the wider pension system develops.
Pensions Goth: Could a clearinghouse for small pot consolidation build on the data infrastructure developed for the dashboard?
Chris Curry: The data standards would help, but the two systems are fundamentally different. The dashboard is entirely driven by the individual: data is only retrieved when a person logs in and proves their identity. A clearinghouse consolidating small pots would operate without the individual being directly involved, which means it needs a different way of identifying pots and a higher standard of proof before acting. The consequences of an error are also different. If the dashboard briefly shows someone another person’s data, that is a serious problem. If a clearinghouse transfers someone’s money into the wrong pension, that is a significantly more serious one. The data standards provide a common foundation that could help both systems, and there may be areas of overlap that emerge over time, but they cannot simply be merged.
Pensions Goth: What is the key lesson from the dashboard programme for other policy areas?
Chris Curry: Dashboards, small pot consolidation, and transfers are connected, but they are not the same problem and do not need the same solution. The most important thing right now is to learn from each one to help with the others.
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