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What’s New in Pension and Benefits – Spring 2026

March 30, 2026 | Evan Shapiro, WTW and Patrick Simon, OPB

LEGISLATION

FEDERAL BUDGET BILL PASSED

Bill C-15, Budget 2025 Implementation Act, No. 1, received Royal Assent on March 26, 2026. It includes amendments to the Income Tax ActIncome Tax Regulations and Excise Tax Act to implement some (but not all) measures announced in the Federal Budget, as well as some previously announced measures (for further details, including effective dates, see our Winter 2026 Update).

DRAFT ITA AND ITR QUALIFIED INVESTMENT RULES

Draft amendments (along with Explanatory Notes) to the Income Tax Act (ITA) and Income Tax Regulations (ITR) have been released and would amend the qualified investment regime for six types of registered plans (RRSPs, RRIFs, TFSAs, FHSAs, RDSPs, and RESPs). These measures were first announced in the 2025 Federal Budget (see our Winter 2026 Update). Most of the amendments will take effect on January 1, 2027, with some amendments relating to FHSAs retroactive to April 1, 2023.

The amendments would consolidate the qualified investment rules for the six registered plans noted above. This includes repealing the rules set out in Part X.2 of the ITA (Tax in Respect of Registered Investments) that currently apply only to certain registered plans, and amending the definition of "qualified investment" in section 207.01(1) to apply to all six types of registered plans. As well, Part XLIX of the ITR (Registered Plans - Investments) would be repealed and replaced by new Part L (Qualified and Prohibited Investments for Registered Plans). Amended section 4900(1) lists the types of property that are qualified investments from November 4, 2025 to the date that Part L takes effect.

Certain prescribed investment rules for DPSPs would also be amended, in generally similar ways, though DPSPs could also hold certain commutable annuities as qualified investments (as is currently the case for other registered plans). Registered plans could also still invest in small businesses, though some rules relating to these investments will change. 

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