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March 2026

Ontario Pension Plans – 2025 Overview

This article was published on December 18, 2025, and was updated on March 3, 2026.

Over 2025, we have closely followed developments related to Ontario pension plans, particularly those involving the Financial Services Regulatory Authority of Ontario (FSRA) and Ontario’s Ministry of Finance. Below is an overview of publications and FSRA activities throughout 2025.

PROPOSED GUIDANCE FOR TARGET BENEFIT PLANS

Effective January 1, 2025, Ontario’s legislation has introduced a permanent target benefit framework for Specified Ontario Defined Benefit Multi-Employer Pension Plans (DB MEPPs). In response, FSRA has issued a proposed guidance on the implementation of this framework and is currently reviewing the feedback received in order to publish a final version.

The guidance details FSRA’s supervisory approach to:

  • Evaluating and approving requests to convert defined benefits to target benefits;
  • Reviewing whether a plan’s provision for adverse deviation (PfAD) aligns with its funding and benefit objectives;
  • Overseeing target benefit plans through regular reviews, risk assessments, and ongoing communications with plan administrators.

It is important to note that administrators of eligible existing DB MEPPs have until December 31, 2029, to submit conversion applications. After this date, conversions will no longer be permitted for these plans, except for new MEPPs or those recently registered with FSRA from another Canadian jurisdiction. In addition, after this date, existing TB MEPPs that no longer meet the TB MEPP eligibility criteria cannot be converted back to target benefits.

VARIABLE LIFE BENEFITS (UNDER CONSIDERATION)

As mentioned in our May bulletin, the most recent Ontario budget highlighted some initiatives regarding Variable Life Benefits (VLBs). The Ontario government has engaged in consultations with a range of pension sector stakeholders to gather perspectives and feedback. Progress on VLBs continues to be closely followed.

AMENDMENT TO ONTARIO’S EMPLOYMENT STANDARDS ACT

Effective June 19, 2025, Ontario’s Employment Standards Act, 2000 introduces “Long-term illness leave.” Eligible employees may take up to 27 weeks of unpaid, job-protected leave within a 52-week period due to serious illness. During this leave, employees can continue participating in their employer’s pension plan if they maintain their contributions, and employers must do the same.

Some pension plans may require an amendment to recognize this type of absence. Therefore, it should require special review to ensure proper administration.

Please note that these changes do not impact the leaves already recognized by the Act, such as maternity leave or sick leave.

ADDITIONAL FSRA PENSION ACTIVITIES IN 2025

Further to FSRA’s guidance on retroactive adverse pension plan amendments published in June 2024, in order to help pension stakeholders understand how conclusions are reached, FSRA has published a summary of amendments that have been approved or not by FSRA.

FSRA has also released several reports in 2025:

Additionally, the Pension Update – November 18, 2025 includes important reminders on areas requiring additional attention concerning buy-out annuity discharge submissions. It also includes a reminder that Incremental Cost Reporting in the Actuarial Information Summary should be reported as an annual average.

Normandin Beaudry consultants will continue to monitor Ontario pension sector news and developments involving FSRA activities and keep you informed. Feel free to contact us if you have any questions.

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