Purpose of consultation:

The Pension Plan Administrator Roles and Responsibilities Guidance (the “Guidance”) provides FSRA’s interpretation of the Pension Benefits Act (“PBA”) on the role and responsibilities of pension plan administrators (“administrators”). Updates were made to enhance the existing Guidance released in July 2021 with the addition of three new sections on records management, complaints handling, and information communication to beneficiaries. The proposed new content is drafted to be principles-based, outcomes-focused, and allow for flexibility in implementation.

Outcome of consultation:

As a result of the consultation, the following changes have been reflected in the final version of the Guidance:

  • Updated the language to clarify where there are paragraphs of the Guidance that establish mandatory compliance requirements (footnote under the Purpose and Scope section).
  • Updated the language to acknowledge that administrator responsibilities may vary in their specifics based on plan type (Purpose and Scope and Role of an Administrator sections).
  • Updated the language to clarify certain statements by FSRA (Who Can be an Administrator, Fiduciary Duties, Service Providers, and Administration Expenses sections).
  • Updated the language to clarify elements that FSRA views as prudent for a plan administrator to consider in order to demonstrate that it has satisfied the standard of care (Records Retention, Complaints and Inquiries, and Providing Information to Beneficiaries sections).

The Guidance will be effective upon publication and will replace the version released in July 2021.

Feedback from the sector:

FSRA received three submissions on the Guidance during the consultation period, which went from August 15 to September 28, 2023. The submission and comments are also available on FSRA’s website.

FSRA thanks all stakeholders who took the time to provide thoughtful comments. FSRA carefully considered all feedback before finalizing and issuing the guidance.


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





Association of Canadian Pension Management (“ACPM”)

Ric Marrero, Chief Executive Officer



Patrick Hatzis, Principal


Ontario Bar Association (“OBA")


Feedback summary and FSRA’s responses: