Update to the actuarial framework surrounding gender identity

The actuarial framework surrounding gender identity has recently evolved with the update to the Canadian Institute of Actuaries’ Standards of Practice (CIA Standards), which came into effect on April 1, 2026, and a clarification published by Retraite Québec on June 15, 2026. This change to the actuarial framework raises issues of particular interest to pension plan administrators, as well as to sponsors of post-retirement group benefits plans.

The CIA Standards now provide important clarifications regarding the use of sex at birth and gender in actuarial work:

• They explicitly recognize the diversity of gender identities;
• They provide flexibility by allowing actuaries to exercise professional judgment when multiple pieces of information regarding gender or sex at birth are available;
• They allow assumptions to be adjusted for non-binary people, such as by using blended mortality rates when appropriate.

These changes are designed to better reflect members’ actual circumstances while upholding a rigorous framework that is consistent with actuarial principles.

For pension plans in Quebec, where the calculation of pension amounts or the value of accrued benefits is based on mortality tables differentiated by sex, Retraite Québec has clarified the approach to adopt for a non-binary person, thereby providing concrete guidance on how to apply the CIA Standards in this context.

The information published on June 15 states that administrators must refer to the sex appearing on an official document issued by the Directeur de l’état civil when applying current legislation. However, for a non-binary person, Retraite Québec expects blended male and female mortality rates (50%–50%) to be used for administrative calculations.

In other Canadian provinces, where the value of benefits is generally determined using unisex tables, administrative calculations are not impacted. At this time, legislators have not released any publications.

The recent updates may raise questions regarding the continued use of sex-specific mortality tables. Although the use of unisex tables may seem simpler from an administrative standpoint, the use of separate tables allows for the recognition of differences in life expectancy. According to the most recent mortality tables (see our March 2026 bulletin), life expectancy still differs significantly for men and women. The use of blended mortality rates may therefore lead to differences in outcomes that could disadvantage women, as their longer life expectancy means benefits must be funded over a longer period.

These changes require concrete adjustments from both an administrative and actuarial standpoint. In this context, this is an appropriate time to review current practices.

In particular, updates may need to be made to forms, data collection practices, and administrative systems in order to accurately convey the relevant information.

From an actuarial perspective, changes may be observed for Quebec pension plans in terms of actuarial valuation programs, transfer value calculations, and certain actuarial equivalencies.

In a broader sense, this initiative provides an opportunity to implement more inclusive practices around gender diversity, while complying with the regulatory framework.

Leverage our expertise in pension plans, group insurance, and diversity, equity and inclusion to obtain support in implementing these changes. Contact us to find out more.