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    2025-04-01

PDCOB 12.1 Purpose

PDCOB 12.1.1 G

1The purpose of the rules in this chapter is to place specific additional requirements on firms that offer post-view services.

PDCOB 12.3 Permitted post-view services

PDCOB 12.3.1 R

1A firm must only offer or provide post-view services that:

  1. (1)

    relate to pensions and retirement planning or are a type of service that supports customers in understanding their pensions and view data to enable them to better understand and consider their retirement planning;

  2. (2)

    have been user-tested in accordance with PDCOB 12.6.1R;

  3. (3)

    do not include:

    1. (a)

      an offer to sell (which includes sending an application form for a product);

    2. (b)

      an offer to arrange for the sale or purchase of;

    3. (c)

      selling; or

    4. (d)

      arranging for the sale or purchase of (which includes sending an application form for a product),

    an investment to or for a customer; and

  4. (4)

    do not include investment advice or advising on pension transfers and pension opt-outs .

PDCOB 12.3.2 G

1A firm is permitted to ask a customer to input data into the post-view service, such that post-view services can be provided, either by way of auto-populated data from the view services, pensions dashboard self-asserted data or a mixture of both.

PDCOB 12.3.3 G

1 Firms are reminded that they may require permission to carry on regulated activities other than regulated pensions dashboard activity if any post-view services amount to regulated activities.

PDCOB 12.3.4 G

1 Firms are reminded that when they provide post-view services, they must comply with their obligations in PRIN, including:

  1. (1)

    acting to deliver good outcomes for retail customers (Principle 12);

  2. (2)

    enabling and supporting retail customers to pursue their financial objectives (PRIN 2A.2.14R); and

  3. (3)

    designing and delivering support to retail customers such that it meets the needs of retail customers, including those with characteristics of vulnerability (PRIN 2A.6.2R).

PDCOB 12.3.5 G

1Pursuant to PDCOB 12.3.1R(4), a firm is not permitted to offer a post-view service which amounts to advising on pension transfers and pension opt-outs. This includes abridged advice. However, a firm is permitted to offer post-view services which support and engage customers with their safeguarded benefits. A firm should ensure that such support and engagement does not stray into the regulated activity of advising on pension transfers and pension opt-outs and should consider the guidance in PERG 2.7.16GG.

PDCOB 12.3.6 G

1 Firms should consider how assumptions about future investment returns and charges can influence customers’ decision-making on transferring or converting safeguarded benefits. Firms should ensure that such assumptions do not result in the firm advising on pension transfers and pension opt-outs.

PDCOB 12.4 Specific fees restrictions in relation to post-view services

PDCOB 12.4.1 R

1A firm must not require the customer to pay for, or to agree to pay for, any post-view service as a condition of accessing their pensions dashboard view data.

PDCOB 12.4.2 G

1 Firms should also refer to the rules on charging in PDCOB 2.5.2R to PDCOB 2.5.8R.

PDCOB 12.4.3 R

1If a firm is charging for a post-view service, and the firm offers the same service significantly cheaper or free of charge outside the pensions dashboard platform, a firm must inform the customer of that fact in good time before providing the post-view service.

PDCOB 12.4.4 G

1A firm which charges for a post-view service is reminded of its obligations under Principle 12. In particular, a firm which charges for a post-view service should be satisfied that their fair value obligations under PRIN 2A.4, the retail customer outcome on price and value, are met.

PDCOB 12.5 Disclosures to be provided to customers in relation to post-view services

PDCOB 12.5.1 R

1A firm must ensure that any offer for post-view services is accompanied by prominent information which:

  1. (1)

    explains the nature and purpose of the post-view service;

  2. (2)

    explains the limitations of the post-view service;

  3. (3)

    explains how customers can raise a query or complaint about the post-view service; and

  4. (4)

    includes the messages required under PDCOB 5.5.

PDCOB 12.5.2 G

1In order to ensure that the nature of the post-view service is not misleading and is capable of being understood by customers, a firm should consider including information which:

  1. (1)

    ensures that customers do not perceive post-view services as giving them guarantees of what their pension(s) will be worth in retirement;

  2. (2)

    ensures that customers do not perceive post-view services as giving them personal recommendations; and

  3. (3)

    where relevant, explains the assumptions underpinning modellers, projections, calculations or similar.

PDCOB 12.6 User testing

PDCOB 12.6.1 R

1The user testing referred to in PDCOB 12.3.1R(2) must be designed to ensure that the nature of the post-view services is capable of being easily understood and easily used and is not likely to mislead or confuse customers.

PDCOB 12.6.2 R

1Where user testing identifies deficiencies in post-view services and/or how they are presented, or improvements which should be made, the firm must make changes to the post-view services to remedy such deficiencies or make such improvements.

PDCOB 12.6.3 G

1A firm should consider whether further user testing is necessary when a material change has been made to any post-view services which it provides.

PDCOB 12.7 Use of data

PDCOB 12.7.1 R

1Save for the circumstances in PDCOB 12.7.2R, a firm must not share customers’ information, including the outcome of post-view services, with any other person.

PDCOB 12.7.2 R

1A firm may share customers’ information, including the outcome of post-view services, with a third party with which a firm has entered into an outsourcing arrangement concerning any service or activity in connection with its qualifying pensions dashboard service where necessary and to the extent necessary to provide a post-view service.

PDCOB 12.8 Access to the results of post-view services

PDCOB 12.8.1 R

1A firm must allow a customer to receive a copy of the results of the post-view service, where applicable, and where the firm is not restricted by the rules in relation to data export in PDCOB 11.

PDCOB 12.8.2 G

1A firm should transfer the results referred to in PDCOB 12.8.1R securely to the customer. Firms are reminded of their obligation to comply with the principle of integrity and confidentiality in article 5(1)(f) of the General data protection regulation.