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CP24/4: Further consultation on the regulatory framework for pensions dashboard service firms

What has happened?

In March 2024, the FCA publicised that operating a pensions dashboard service is a new regulated activity and that it is consulting in its CP 24/4 on guidance for firms undertaking this new activity and on two changes to the rules it originally proposed for these firms in its Consultation Paper CP22/25.

Pension dashboards will be secure digital interfaces that allow consumers to find their pensions and to view basic information about them. To ensure an appropriate degree of consumer protection for users of private sector pensions dashboards, the Government recently amended the Regulated Activities Order (RAO) to bring the activity of operating a pensions dashboard service within FCA regulation.

What are the key points of the Consultation Paper?

The FCA is proposing to include guidance in its Perimeter Guidance Manual (PERG) to help firms understand the scope of this new regulated activity and when FCA authorisation and permission is required. This guidance is designed to help firms understand the scope of this new regulated activity and when they will require permission to undertake.

It is also inviting feedback on two proposed changes to the proposals in the December 2022 CP22/25.

This consultation primarily affects firms interested in operating a pensions dashboard service and needing to seek the new regulatory permission.

The FCA is inviting feedback on the proposals, including the draft Handbook text in Appendix 1, and it has requested comments by 8 May 2024. It will consider feedback to both CP22/25 and this further consultation before finalising the full set of rules and the perimeter guidance and publishing a policy statement. Subject to consultation feedback and external dependencies, the FCA aims to publish these in Q4 2024.

How can we help you? 

Thistle Initiatives has supported pension firms for over 10 years as a trusted compliance and regulatory adviser. In addition to assisting firms as-and-when, our team of specialists can serve as your right hand in meeting and complying with FCA regulations. We understand the importance of staying up-to-date and compliant and are dedicated to providing the guidance and support needed to do so.

Are you looking for help with your pension dashboard arrangements, or more general regulatory questions?

If so, we can help in any of the following ways;

  • Reviewing whether your firm will require the new permission,
  • Assisting you with an FCA application for the permission.
  • Interpreting the new rules and what they mean for your firm,
  • Advising you on incorporating the new activity into your governance and compliance framework,
  • Reviewing current work in various stages of development, both in the FCA and the Government, that could change the dashboard landscape in the future. Examples of this include the joint Treasury and FCA review of the Advice Guidance Boundary (AGBR), and the Department for Work and Pensions’ Small Pots Solution.

Contact our specialist team now to schedule a free consultation. Get in touch with us by calling 020 7436 0630 or sending an email to