New Regulation Adopted: Variable Payment Life Pension Funds Coming to Plans as of 2026

The Regulation to amend the Regulation respecting supplemental pension plans to establish the framework governing the implementation of variable payment life pension funds (“VPLP”) in defined contribution (“DC”) plans was adopted by the Government of Québec and published in the Official Gazette of Québec on December 17, 2025. It will come into effect on January 1, 2026.

This regulation stems from an initial draft published in the Official Gazette of Québec on May 28, the key elements of which were summarized in our News and Commentary 25-02. The final version of the regulation introduces few changes compared to the draft version.

The only notable change is the possibility of anticipating changes to the mortality assumptions prior to the preparation of the actuarial report by submitting the new assumptions to Retraite Québec.

Please also note that the Regulation to amend the Regulation respecting voluntary retirement savings plans to provide for the rules governing the establishment of VPLPs and to harmonize the rules governing the disbursement of variable benefits with those already in force since January 1, 2025 for DC plans and life income funds (LIFs) has also been adopted and will also come into force on January 1, 2026.