A pension plan is a regulated trust, not just a benefit
A Group RRSP is a collection of individual RRSPs; the provider does most of the legal heavy lifting. A defined contribution pension plan (DCPP) is different. It is a registered pension plan under the Income Tax Act and is also registered with a pension regulator under provincial or federal pension standards legislation. The employer that sponsors the plan is usually also its administrator, and the administrator carries legal obligations to plan members, including a standard of care that pension law describes in fiduciary terms.
Which regulator applies to your plan
Your plan is regulated by the jurisdiction where most of your active members work, or federally if you operate in a federally regulated industry such as banking, telecommunications, or interprovincial transportation. In Alberta, plans are governed by the Employment Pension Plans Act (EPPA) and overseen by the Office of the Alberta Superintendent of Pensions. In Ontario, plans fall under the Pension Benefits Act (PBA), administered by the Financial Services Regulatory Authority of Ontario (FSRA). Federally regulated plans fall under the Pension Benefits Standards Act, 1985 (PBSA), supervised by the Office of the Superintendent of Financial Institutions (OSFI). Members working in other provinces are still protected by their own province's minimum standards.
What CAPSA Guideline No. 3 expects
The Canadian Association of Pension Supervisory Authorities (CAPSA) sets out expectations for capital accumulation plans, including DCPPs, in Guideline No. 3. The revised guideline was released in September 2024 and replaced the 2004 version, with full implementation expected by January 1, 2026. It asks sponsors to select and monitor service providers, choose and regularly review the investment options offered to members, provide members with clear information and decision-making tools, and review fees and plan performance on an ongoing basis. The guideline also acknowledges that a sponsor's responsibilities may be fiduciary in nature in some cases. It is guidance rather than statute, but regulators use it as a benchmark for good practice.
Governance and the role of a pension committee
Most DCPP sponsors delegate day-to-day oversight to a pension committee, typically a small group drawn from HR, finance, and senior management. The committee meets on a regular schedule, reviews investment options and performance, monitors service providers and fees, oversees member communications, and keeps minutes that document its decisions. CAPSA's governance guidance sets the expectation that plans have a clear governance structure, defined roles, and a process for self-assessment. In Alberta, every plan is also required to have a written governance policy.
Investment oversight
Administrators are expected to document how the plan's investments are selected and monitored, usually in a statement of investment policies and procedures (SIP&P). For a DC plan with member choice, that means deciding which funds appear on the menu, what the default option is for members who don't choose, and how often the lineup is reviewed. If a fund underperforms or its fees are out of line, the committee is expected to act. Doing nothing is itself a decision that can be scrutinized.
Contributions, statements, and annual filings
Administrators must ensure contributions are deducted and remitted to the plan's fund holder on time, generally within 30 days of the end of the month they relate to, and that employer contributions follow the plan text. Members must receive annual statements; in Alberta, within 180 days of the plan's fiscal year end. Each year the plan also files an Annual Information Return with its regulator. In Alberta, the AIR is due within 180 days of the plan's fiscal year end, and late filings attract a penalty. Other jurisdictions have similar deadlines. Plan amendments must be filed with both the regulator and the CRA, and pension adjustments must be reported on each member's T4.
How LINK reduces the load
LINK administers the plan platform and member experience for DCPP sponsors, and LINK's wholly owned subsidiary, a registered portfolio manager, places each member in a suitable portfolio. Your plan specialist can walk you through which responsibilities remain with you as sponsor. For employers who want a DC pension without taking on plan sponsorship at all, the LINK Multi-Employer Pension Plan is designed for exactly that.