Summary of stakeholder comments – Supervisory Approach Guidance to Implementation of the Target Benefit MEPP Framework | Financial Services Regulatory Authority of Ontario

Purpose of consultation

The Financial Services Regulatory Authority of Ontario (FSRA) is supporting the implementation of the permanent Target Benefit (TB) Framework under the Pension Benefits Act (PBA) and its regulations. This consultation is part of FSRA’s ongoing efforts to promote transparency, consistency, and sound governance practices in the administration of multi-employer pension plans (MEPPs) providing target benefits.

The Supervisory Approach Guidance to Implementation of the Target Benefit MEPP Framework outlines FSRA’s supervisory approach to:

consent requirements for converting defined benefits to target benefits
assessment of the provision for adverse deviation (PfAD) for TB MEPPs
supervisory engagements with TB MEPPs under the new framework

This consultation follows the January 1, 2025, legislative changes which are replacing the temporary specified Ontario multi-employer pension plan (SOMEPP) regulations with the permanent TB Framework. FSRA is working to ensure that, where plan administrators elect to convert benefits to target benefits under the TB Framework, they and other stakeholders are informed of their responsibilities and prepared to comply with the relevant requirements.

Outcome of consultation

No changes were made based on the stakeholder feedback received and FSRA has finalized its Supervisory Approach Guidance to support the implementation of the TB Framework. The final Guidance reflects a risk-based, transparent approach and incorporates input received during the Guidance development and consultation process.

The Guidance will be effective February 2, 2026, and is intended to help administrators and stakeholders navigate the new framework with confidence.

Feedback from the sector

FSRA has engaged extensively with stakeholders throughout the development of its approach to the TB Framework. This consultation process has been collaborative, with meaningful input received through Technical Advisory Committees (TACs) and other stakeholder engagement channels.

Feedback has emphasized the importance of a transparent supervisory approach, practical guidance on funding requirements, and continued dialogue as the sector transitions from the temporary SOMEPP regime. FSRA has considered this input carefully and has incorporated it into the development of the Guidance.

FSRA received one submission during the consultation period. The submission is available on FSRA’s website.

Contributors

The following stakeholder took the time to share their perspectives with FSRA:

Organization	Commenter
General Synod Pension Plan (GSPP)	Rekha Menon

Feedback summary and FSRA’s responses

Multijurisdictional restrictions

Stakeholders	Summarized comment	FSRA’s response
GSPP	The stakeholder submitted that the Guidance should include further information on how FSRA will assess which jurisdictions prohibit the reduction of benefits for multijurisdictional plans under the TB Framework. The stakeholder further requested clarification on how the 10% threshold would be monitored and reported.	Since the legislative frameworks of other jurisdictions can evolve, plan administrators should be closely monitoring the rules in other jurisdictions. It is FSRA’s view of these requirements that where a jurisdiction allows benefit reductions based on the consent of the regulator and/or members, this would not qualify as a prohibition on the reduction of benefits for that jurisdiction. Similarly, where a plan is granted a ministerial exemption from that jurisdiction’s restrictions on benefit reductions, there would not be a prohibition on benefit reductions for that jurisdiction. Given the various rules across jurisdictions affecting multijurisdictional plans, FSRA encourages plan administrators to work closely with FSRA and other jurisdictions’ regulators to demonstrate compliance with this eligibility criteria. Finally, similar to other ongoing eligibility criteria for plans operating under the target benefit framework, it is the responsibility of plan administrators to ensure the plan continues to meet eligibility criteria, and FSRA will assess these criteria as part of its ongoing supervisory activities. FSRA encourages plan administrators to take early and preventative measures if an administrator believes the plan’s employer or member composition may compromise its eligibility under the framework.

Stakeholders

Summarized comment

FSRA’s response

GSPP

The stakeholder submitted that the Guidance should include further information on how FSRA will assess which jurisdictions prohibit the reduction of benefits for multijurisdictional plans under the TB Framework. The stakeholder further requested clarification on how the 10% threshold would be monitored and reported.

Since the legislative frameworks of other jurisdictions can evolve, plan administrators should be closely monitoring the rules in other jurisdictions.

It is FSRA’s view of these requirements that where a jurisdiction allows benefit reductions based on the consent of the regulator and/or members, this would not qualify as a prohibition on the reduction of benefits for that jurisdiction. Similarly, where a plan is granted a ministerial exemption from that jurisdiction’s restrictions on benefit reductions, there would not be a prohibition on benefit reductions for that jurisdiction.

Given the various rules across jurisdictions affecting multijurisdictional plans, FSRA encourages plan administrators to work closely with FSRA and other jurisdictions’ regulators to demonstrate compliance with this eligibility criteria.

Finally, similar to other ongoing eligibility criteria for plans operating under the target benefit framework, it is the responsibility of plan administrators to ensure the plan continues to meet eligibility criteria, and FSRA will assess these criteria as part of its ongoing supervisory activities. FSRA encourages plan administrators to take early and preventative measures if an administrator believes the plan’s employer or member composition may compromise its eligibility under the framework.