Vol. 149, No. 8 — April 22, 2015


SOR/2015-79 April 1, 2015


Regulations Amending the Canada Pension Plan Regulations

P.C. 2015-403 April 1, 2015

His Excellency the Governor General in Council, on the recommendation of the Minister of Employment and Social Development, pursuant to subsection 89(1) (see footnote a) of the Canada Pension Plan (see footnote b), makes the annexed Regulations Amending the Canada Pension Plan Regulations.



1. Section 43.1 of the Canada Pension Plan Regulations (see footnote 1) is repealed.


2. These Regulations come into force on June 1, 2015.


(This statement is not part of the Regulations.)


The Government of Canada is committed to streamlining and modernizing the delivery of services for Canadians, including via electronic service delivery for the Canada Pension Plan (CPP). Acting on this commitment, recent amendments to the Department of Human Resources and Skills Development Act (DHRSD Act), (see footnote 2) and subsequent introduction of the Electronic Documents and Electronic Information Regulations (EDEI Regulations), established the necessary parameters within which to provide and expand electronic service delivery. A legal requirement, under section 43.1 of the Canada Pension Plan Regulations (CPP Regulations), which required CPP retirement pension applicants to physically sign and submit a one-page form, is therefore no longer necessary, and has become an impediment to proceeding with full automation of the CPP retirement pension application process.


Since 2004, CPP retirement pension applicants have had the option of completing their applications using a traditional paper-based process, or a two-step online process. The two-step online process allowed applicants to first complete the application online and submit it to the Minister. The online system then provided the applicant with a confirmation sheet, indicating the date and time that the application was received by the Minister, which had to be printed, signed (the wet signature) and physically returned (by hand, mail or courier) to the Department of Employment and Social Development (DESD). The two-step process only applied to CPP retirement pensions; other CPP benefits (i.e. disability, survivor, children’s, and death) were not available online as the system did not have the capacity to electronically receive the necessary evidence in support of these applications.

The requirement for a wet signature reflected certain limitations which prevented full automation of the CPP retirement pension application process in a legally sound and technologically secure manner.

Budget 2012 committed to consolidating, standardizing and automating administrative functions to reduce duplication and increase capacity to offer advanced services and transactions online. Acting on this commitment, the Jobs, Growth and Long-term Prosperity Act, which received royal assent in June 2012, amended the DHRSD Act to add provisions authorizing service delivery by electronic means (now sections 70.1 to 73 of the Department of Employment and Social Development Act [the DESD Act]). These amendments also provided the Governor in Council with the authority to make regulations with respect to electronic signatures (e-signatures). Establishing the parameters within which to provide and expand electronic service delivery, the EDEI Regulations were made on June 4, 2014. These amendments provide the necessary legal underpinnings for e-signatures.

There are two distinct processes when providing a secure, client-authenticated electronic service: client authentication and subsequent confirmation that the client has the intent to apply (an e-signature). Client authentication requires clients to access DESD’s online services to register for a Government of Canada approved credential (GC Key or Secure Key), a process which includes the receipt of a secure access code by physical mail. Once a client has successfully registered, that client will have the ability to apply for the CPP retirement pension using My Service Canada Account. The relevant personal information will be displayed and the client asked to verify the information and subsequently confirm the intent to apply for the retirement benefit. It is this confirmation of client intent that effectively serves as the client’s e-signature.

These processes adopt the standards of DESD’s Identity Management Policy Suite and align with the Government of Canada’s Policy on Government Security, as well as the Treasury Board’s Directive on Identity Management. In conjunction with Shared Services Canada, DESD ensures that the Government of Canada information technology security policies and protocols are respected.


The objective of the Regulations amending the Canada Pension Plan Regulations (the amendments) is to remove a final legal impediment to implementation of online services for CPP retirement pension applications.


The amendments remove the requirement for the wet signature by repealing section 43.1 of the CPP Regulations, and allow the CPP retirement pension application to become fully automated.

“One-for-One” Rule

The “One-for-One” Rule does not apply to this proposal, as there is no change in administrative costs to business.

Small business lens

The small business lens does not apply to these amendments, as there are no costs to small business.


The amendments to the DHRSD Act, enabling these services, were considered by Parliament in June 2012 in the context of review of the Jobs, Growth and Long-term Prosperity Act, and discussed in committee. No concerns were raised during these deliberations. The EDEI Regulations were published in the Canada Gazette, Part I, on December 14, 2013, followed by a 30-day public comment period. No changes to the EDEI Regulations were required as a result of the comments received.

Given that the authority to implement full electronic service delivery for CPP retirement pension applications has already been approved in legislation and regulation, with opportunities for public comment, and that the amendments simply remove an unnecessary impediment to full implementation, with no associated impacts, subsequent consultations were unnecessary.


Electronic service delivery is a government priority, as announced in Budget 2012. This priority is reflected in amendments to the DHRSD Act in 2012, the making of the EDEI Regulations in 2014, and these amendments.

The ability to apply fully online will improve service to Canadians and generate significant administrative efficiencies and cost savings in the delivery of the CPP program. The amendments do not directly generate these efficiencies and savings, but remove an unnecessary impediment to the implementation of full automation. Removal of the wet signature requirement would eliminate the need for CPP retirement pension applicants to print, sign and return to DESD the application confirmation sheet, resulting in the removal of an administrative burden for retiring Canadians. The migration to full automation, enabled by the amendments, would also generate approximately $1 to 2 million in annual savings in CPP processing. Applicants retain the option of completing CPP retirement applications in writing; however, clients will be encouraged to use the online application instead.


Marianna Giordano
CPP Policy and Legislation
Seniors and Pensions Policy Secretariat
Employment and Social Development Canada
140 Promenade du Portage, Phase IV, 8th Floor
Gatineau, Quebec
K1A 0J9
Telephone: 819-654-1672
Fax: 819-953-9298
Email: marianna.giordano@hrsdc-rhdcc.gc.ca