While the Jan. 1 deadline for CAP sponsors to bring their systems and processes into compliance with the Canadian Association of Pension Supervisory Authorities’ updated guideline No. 3 has come and gone, compliance with the CAP guideline will continue in 2026 and beyond.

Good governance is a prominent theme throughout the updated CAPSA guideline. Governance is the vehicle to maintain oversight of the CAP and support processes to review service providers, investment options, member communication, member education and decision-making tools.  If CAP sponsors haven’t conducted an audit to confirm compliance with the CAP guideline, there’s no better time than now to review the guidelines and implement a written governance structure that’s proportionate to their particular CAP based on size and complexity.

Read: 2025 CAP Suppliers Report: How are Canadian plan sponsors complying with the CAPSA’s updated guideline?

For CAP sponsors that have confirmed their current governance framework complies with the guideline or have made enhancements to their existing framework and/or processes for compliance, they should review their existing or enhanced governance framework in 2026 to determine whether the framework supports the oversight of the CAP in the manner set out in the guideline. The updated guideline is prescriptive in the oversight of the CAP, including various factors to consider when reviewing the CAP’s features, the performance of service providers and investment options and the effectiveness of member communication, member education and decision-making tools.

A CAP sponsor’s........

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