Penalties more than doubled, and a new accountability proposal is open for comment
Contributions at 301 pension plans stayed unpaid for 30 days or more in 2025-26, according to OSFI's annual report published October 13, 2026.
The report covers April 1, 2025, to March 31, 2026. In that year, the Office of the Superintendent of Financial Institutions oversaw approximately 350 federally regulated financial institutions and about 1,200 pension plans holding $276 billion in assets.
Late contributions get a nudge from OSFI
Under the Pension Benefits Standards Act, 1985, the 301 plans missed minimum funding requirements because required contributions were outstanding for 30 days or more. OSFI responded with late remittance letters reminding employers of their obligations.
In 10 cases, the money stayed unpaid for an extended period. Where warranted, OSFI escalated through notices of intent and/or directions of compliance. Four plans then paid what they owed, with interest, and OSFI said it kept working with the remaining six toward compliance.
The wider picture is brighter. The estimated median solvency ratio of pension plans climbed to 1.28 at year-end 2025, up from 1.20 in 2024, and 93% of plans were fully funded on a solvency basis. The share of underfunded plans slipped to 7% from 8%.
Senior leaders, AI models and crypto in the spotlight
Bank and insurance executives have a proposal to read. On January 29, 2026, OSFI opened a consultation on a proposed senior leader regime, which would modernize suitability and accountability expectations for senior leaders of federally regulated financial institutions. Comments are due October 31, 2026.
Firms leaning on AI also have a date to circle. Guideline E-23 on model risk management, issued September 11, 2025, takes effect May 1, 2027, with an 18-month transition period, and covers risks tied to AI and machine learning. OSFI also introduced an expectation for banks to disclose their crypto-asset exposures and launched a consultation on credit risk that names private credit as an emerging risk.
On bank capital, OSFI held the Domestic Stability Buffer at 3.5% of risk-weighted assets in June and December 2025, and average Common Equity Tier 1 ratios came in at approximately 13.6%, above the 11.5% supervisory expectation. The buffer and its range were lowered in June 2026, the report notes. "Today, Canada's six largest banks hold capital levels well above supervisory expectations," Superintendent Peter Routledge said in the report.
Penalties rise while OSFI tightens its belt
OSFI levied $1.247 million in administrative monetary penalties on financial institutions in the year ended March 31, 2026, up from $530,000 the year before. The report does not name the institutions involved. Penalty money goes to the Consolidated Revenue Fund and does not lower the assessments OSFI charges the industry.
The regulator also trimmed its own team. A workforce adjustment launched September 4, 2025, eliminated 82 positions, with about $12.1 million in related costs. Total costs reached $332.6 million, up 5.8%, while base assessments on financial institutions rose $18.4 million, or 6.6%.
Next on OSFI's radar, under its 2026-27 Annual Risk Outlook, are real estate secured lending, non-bank financial intermediation, and funding and liquidity. On pensions, the report reminds readers that "pension plan administrators bear the responsibility for the sound and prudent management of their pension plans." The full text of the OSFI Annual Report 2025-2026 is available at https://www.osfi-bsif.gc.ca/en/about-osfi/reports-publications/osfi-annual-report-2025-2026?utm_source=web&utm_medium=email&utm_campaign=osfi-bsif-email. For advisors planning clients' retirement income, the report also carries this from Chief Actuary Assia Billig: "The findings of 32nd Actuarial Report on the Canada Pension Plan reaffirm that the Canada Pension Plan is on solid financial footing and will continue to provide reliable retirement income for Canadians for decades to come."
