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ARTICLE · 15 AUGUST 2025

Retroactive Pension Plan Amendments: How FSRA Is Applying Its Guidance

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Last year, the Financial Services Regulation Authority of Ontario released its Pension Plan Amendments Guidance, offering insight into how FSRA interprets and administers the Pension Benefit Act (Ontario) provisions related to retroactive amendments.

CanadaEmployment and HR
Jenifer Elmy
Jenifer Elmy
Stephanie Kalinowski
Stephanie Kalinowski
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Last year, the Financial Services Regulation Authority of Ontario (FSRA) released its Pension Plan Amendments Guidance (the Guidance)1, offering insight into how FSRA interprets and administers the Pension Benefit Act (Ontario) (PBA) provisions related to retroactive amendments. As of March 31, 2025, FSRA has reviewed 17 retroactive amendment applications with a negative impact, and registered eight. While FSRA has indicated that these decisions should not be considered precedent for future cases, pension plan sponsors and administrators contemplating plan amendments may find it helpful to review the factors FSRA identified in its decision-making to ensure compliance.

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