Federally regulated pension plans excluded from scope of OSFI's Guideline E-23 – Model Risk Management
October 14, 2025
Canada’s Office of the Superintendent of Financial Institutions (“OSFI”) has excluded federally regulated pension plans from the scope of its final Guideline E-23 – Model Risk Management.
Earlier drafts of Guideline E-23 indicated that it would apply to federally regulated pension plans (“FRPPs”), but the final version, published on September 11, 2025, was amended to exclude FRPPs from the application of Guideline E-23 following feedback from stakeholders.
OSFI explained that FRPPs were excluded as a result of their distinct supervisory framework compared to financial institutions, as well as OSFI’s expectation — expressed in a 2024 letter — that administrators of FRPPs will follow the Canadian Association of Pension Supervisory Authorities’ Guideline No. 10: Guideline for Risk Management for Plan Administrators (“CAPSA Risk Management Guideline”).
The CAPSA Risk Management Guideline covers similar ground to OSFI’s Guideline E-23, setting out principles of risk management and outlining a risk management framework to assist pension plan administrators in fulfilling their fiduciary duties.
Click ‘More Information’ below to review the Guideline:
