In May 2025, the Pension Commission of Manitoba put out a call for comments on its five-year review of the province’s Pension Benefits Act of Manitoba. In response, organizations including the Canadian Institute of Actuaries (CIA) and the Association of Canadian Pension Management (ACPM) have weighed in on a number of topics including the regulation of variable payment life annuities (VPLAs), annuity discharge legislation and pension unlocking provisions.

In its call for comments (the closing date for submissions passed in late June), the commission discusses expanding current unlocking provisions, ways to improve both defined benefit (DB) and defined contribution (DC) pension plans in the province, VPLAs, and whether the province should permit registered DC plans to offer the option of transferring a plan member’s pension to a VPLA when the plan member terminates employment.

It also considers annuity discharge legislation – unlike other provinces, in Manitoba, plans purchasing annuities are not relieved of their obligations to members if the insurer’s business fails.

Canadian Institute of Actuaries

In response, the CIA took the opportunity to discuss current unlocking provisions, saying a simplification of the rules is essential to promoting a better understanding among the public. They add that such a move would also foster more judicious use of the applicable rules.

The CIA submission also discusses solvency funding for multi-unit pension funds and specified multi-employer pension plans. It advocates for the establishment of frameworks to allow target benefit plans and it encourages Manitoba to amend legislation to authorize VPLAs and advanced life deferred annuities (ALDAs) in the province. 

“VPLAs have the potential to become an important part of the retirement system, since they could allow the growing number of Manitobans in DC plans to decumulate their assets in an orderly fashion, protect themselves against longevity risk and receive an adequate retirement income,” they write, noting that VPLAs will be more effective if they are allowed to achieve greater scale. “ALDAs also have the potential to be an important tool for DC plan members to manage longevity risk.” 

In matters of governance, the CIA also advocates for the province to review the administrative burden that its pension committee governance requirement – namely the need for a administrative governance pension committee – places on small plans. “We see the CAPSA (Canadian Association of Pension Supervisory Authorities) governance guidelines as a useful starting point, but plan sponsors and administrators should be encouraged to develop or adapt a governance policy that suits their circumstances.” 

The organization also suggests that the province do more to promote financial planning and harmonize its regulations with those in other jurisdictions.

Association of Canadian Pension Management

The ACPM also weighed in during the consultation, saying the organization generally advocates for restricting pension unlocking to ensure that pension savings remain largely for their intended purpose. That said, they add that the organization is also in favour of harmonization.

“Given that full unlocking from LIRAs and LIFs (locked-in retirement accounts and life income funds) is already permitted at age 65 in Manitoba, we believe that expanding this provision to include full unlocking directly from a pension plan at age 65, if permitted by the plan, would simplify the overall process for members reaching retirement and seeking to access their pension benefits, aligning all locked-in retirement savings vehicles under a consistent unlocking threshold at age 65,” they write. “We emphasize that any such provision of a pension plan should be entirely optional for plan sponsors.” 

To improve both DB and DC plans the organization advocates for harmonized legislation. Target benefit plans are also discussed saying these plans are a viable model for providing income to members and cost certainty for plan sponsors. “We therefore support legislative amendments to enable this plan design to exist in Manitoba.” 

They add that the association was encouraged by the inclusion of VPLAs in the province’s consultation paper. Financial statement requirements, electronic beneficiary designations, better regulation of simplified money purchase plans (SMPPs), and the development of a missing plan member registry are all also discussed in the organization’s submission.

Currently in Manitoba there are 71 DB pension plans serving more than 135,000 active members and 257 DC plans serving more than 60,000 active members.