Ontario has announced a one year delay in implementing the
Ontario Retirement Pension Plan (ORPP) for certain employers with
500 or more Ontario employees. Ontario and the federal government
also announced plans to continue national discussions about Canada
Pension Plan (CPP) enhancements.
As outlined in our November 10, 2015, ORPP and CPP: Pension
Reform Update, the ORPP was originally scheduled to be
implemented in four annual waves commencing on January 1, 2017. The
wave classification is determined by the number of an
employer's Ontario employees who did not have a registered
pension plan as of August 11, 2015.
The first wave covers employers with 500 or more such employees
and ORPP contributions for these employees was scheduled to
commence on January 1, 2017. This contribution date has now been
delayed until January 1, 2018. The contribution commencement date
for the other waves remains the same: waves 2, 3 and 4 will be
phased in, respectively, on January 1 of 2018, 2019 and 2020.
Employer enrolment is scheduled to commence in January 2017.
Coordinating with CPP Enhancements
In a joint announcement with the federal government,
the Ontario government announced that the delay will give federal
and provincial governments more time to discuss how to enhance the
The federal government announced that if provincial agreement on
CPP enhancement is not reached, it will work with Ontario as
Ontario implements the ORPP by facilitating plan registration, data
sharing and contribution collection.
Ontario continues to hedge its bets. As Minister of Finance
Charles Sousa put it, "Our main objective is to intensively
look at ways to meet the goals of the ORPP in an enhanced CPP
framework while preserving our ability to implement the ORPP,
should that not be possible."
In the meantime, employers should continue to plan for the
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Unfortunately, reasonable accommodation for employees in the workplace continues to be the source of significant litigation and even today we continue to see outrageous examples of employers behaving badly.
We are now beginning to see reported cases involving charges and subsequent fines laid against employers for failing to provide information, instruction and supervision to protect a worker from workplace violence.
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