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September 2020

Ontario registered pension plans: Temporary relief measures for employers

On September 21, 2020, the Ontario government announced the option to defer contributions to certain defined benefit pension plans for eligible private sector employers to support their stability and sustainability, while guaranteeing the funding of the members’ benefits.

Summary of measures
  • Option to defer for up to six months pension plan contributions required to be made between October 1, 2020, and March 31, 2021.
  • However, all deferred contributions must be paid with interest in accordance with a schedule by March 31, 2022.
Contributions eligible for deferral
  • The normal cost
  • The provision for adverse deviations in respect of the normal cost
  • Eligible special payments
Examples of pension plans ineligible for contribution deferral
  • Multi-employer pension plan
  • Jointly sponsored pension plan
  • Designated plan
  • Individual pension plan


Employers electing to defer one or several contributions must file an election and schedule of payments prepared by the plan’s actuary with the Financial Services Regulatory Authority of Ontario (FSRA) no later than the date on which the contributions for the first deferred month are due. This election must also include additional information about the pension plan, specifically:

  • The estimated transfer ratio
  • The value of the solvency assets
  • The estimated solvency liabilities

The funds made available by this measure must be used strictly to maintain business operations. Employers are restricted from certain activities and FSRA will ensure compliance. These activities will no longer be restricted once all deferred contributions are repaid. Early repayment is allowed.

Finally, pension plan sponsors will also have 120 days, instead of 60 days, to make a “catch-up” contribution if an actuarial valuation is filed on or before April 1, 2021.

To this end, FSRA updated their Q&A, which was released in response to the COVID-19 pandemic and addresses various issues for pension plan administrators and sponsors.

Normandin Beaudry consultants will continue to monitor the pension sector news and will keep you informed of any developments. If you have any questions, contact us.