Find out how this modification works for firms, and how to take advantage of it.
How this modification works
This modification enables firms to connect to the MaPS (Money and Pensions Service) pensions dashboards digital architecture before 31 October 2026, in line with the ‘connect by’ dates in the Department for Work and Pensions connection guidance (Pensions dashboards: guidance on connection: the staged timetable), even where they are unable to connect, and comply with COBS 19.11, for 100% of their relevant pension scheme members’ data.
The unmodified rules under COBS TP 2.38R & COBS TP 2.38BR state that if a firm completes connection to the MaPS pensions dashboards digital architecture before 31 October 2026, that firm must comply with all the obligations under COBS 19.11. This may be problematic for firms that are able to connect by the ‘connect by’ dates in the Department for Work and Pensions connection guidance but are unable to comply with COBS 19.11 for 100% of their relevant pension scheme members.
The relevant dates in the Department for Work and Pensions connection guidance are 30 April 2025 for firms with 5,000 or more relevant members and 31 January 2026 for firms with fewer than 5,000 relevant members.
What this modification means for firms
The Department for Work and Pensions published guidance on 25 March 2024, setting out a staged timetable for connection to the MaPS digital architecture with connection deadlines depending on the size of the scheme. FCA-regulated operators of relevant personal and stakeholder pension schemes must have regard to the guidance when preparing to connect to the MaPS dashboards digital architecture and to comply with the requirements of COBS 19.11 in the FCA’s Handbook.
Connecting to the MaPS pensions dashboards digital architecture in line with the ‘connect by’ dates in the guidance will facilitate the Pensions Dashboards Programme to carry out critical user testing at scale and pace. We acknowledge the unmodified rules may deter firms from connecting by the DWP guidance ‘connect by’ dates of April 2025 and January 2026 where they are unable to comply with COBS 19.11 for 100% of their relevant pension scheme members.
Through this modification, a firm can ensure compliance with COBS 19.11 where they connect before 31st October 2026 (in line with the ‘connect by’ dates) but are unable to comply with COBS 19.11, for 100% of its relevant pension scheme members’ data.
The Direction includes guidance that, if a firm connects before 31 October 2026 in reliance on this modification, we would generally expect the firm to be in a position to comply with all of the provisions in COBS 19.11 from the date of connection in respect of at least 80% of its relevant pension scheme members.
This modification is valid until 31 October 2026 from the start date of the direction, unless subsequently withdrawn.
How to use this modification
You can take advantage of this modification by consent by emailing: [email protected]
We will then write to you to confirm that the modification is active. We will also publish each modification direction we grant on our website.