On 27 March 2024, the FCA published a Consultation Paper, CP24/4, setting out proposed guidance and changes to the regulatory framework for pensions dashboard service firms.


Pensions dashboards will be digital interfaces which allow consumers to find their pensions and view basic information about them in one secure place. The Government has created the legislative framework for this and tasked the Money and Pensions Service’s delivery programme, the Pensions Dashboards Programme, with setting standards for how dashboards should be delivered.

In order to ensure an appropriate degree of consumer protection for users of private sector pensions dashboards, the Government has also amended the Regulated Activities Order to bring the activity of operating a Pensions Dashboard Service (PDS) within FCA regulation. The effect of this legislative change is that a firm wishing to operate a PDS must:

  • Be or become authorised. 
  • Obtain FCA permission to undertake the new regulated activity.
  • Meet the FCA’s requirements for firms undertaking this activity.

The FCA’s previous Consultation Paper, CP22/25, set out its proposed requirements for operators of PDSs. As the new activity is now defined in legislation, the FCA is now proposing to include guidance in its Perimeter Guidance manual (PERG) to help firms understand the scope of the new regulated activity and when they will require permission to undertake it.

CP24/4 invites feedback on the proposed guidance, as well as on two substantive changes to the regulatory framework proposals in CP22/25. The FCA proposes to:

  • Require firms to present the consumer with choices for their initial next steps after viewing their pensions data on a PDS. It also proposes that firms provide certain communications that will help ensure consumers can take appropriate care when their selected next step takes them outside the regulated PDS.
  • Revise its data export proposals, with the aim of creating a single, consistent route for consumers to share their dashboard data with an FCA regulated investment adviser.

The changes proposed aim to put the consumer in control of the steps they take in relation to their dashboard, as well as reducing the risk of a consumer being biased towards a particular action by a PDS firm’s design and operation. The draft rules and guidance that would give effect to these new proposals are included in the draft Handbook text in Appendix 1 to CP24/4.

Next steps

The deadline for feedback on the FCA’s proposals is 8 May 2024. The FCA will consider responses to both CP22/25 and CP24/4 before finalising its full set of rules and guidance. Subject to the responses it receives, it aims to publish a policy statement and final Handbook text in Q4 2024.