The Canadian Association of Pension Supervisory Authorities’ updated capital accumulation plan guideline led CPP Investments to sharpen accountability and governance risk globally, according to Marina Lodyga, the investment organization’s director of pension and benefits, during a session at Benefits Canada’s 2025 Defined Contribution Plan Summit.
CPP Investments has around 500 workers across eight global offices — in addition to its Toronto headquarters — and five DC plans with a combined $500 million in assets. Due to this international structure, the new CAPSA guideline prompted the organization to consider whether its governance was consistent across jurisdictions.
“We are a global DC sponsor governed by shared principles, but it is not a one-size-fits-all situation.”
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Lodyga outlined the distinction between what CPP Investments governs globally and what’s executed locally since some of its DC plans — one based in Mumbai and the other in Sydney — continue to operate under local legislative and market requirements, while governance expectations around oversight, accountability and documentation are set centrally.
Once the team started tackling the CAPSA work, she found governance practices were consistent across jurisdictions but the signals of accountability — documented roles, escalation and risk ownership — weren’t always expressed with the same clarity. “That’s when we realized this wasn’t necessarily a Canadian implementation exercise, it was a global governance consistency exercise.”
The CPP Investments’ team clarified that the organization remains accountable, added Lodyga, while the committee provides oversight, management executes and service providers deliver. It also reinforced organizational accountability across all of its DC arrangements, even outside of Canada.
The updated guideline also forced the investment organization to review its plan language to tighten and remove all ambiguities in the pension committee’s term of reference, a backbone of governance for most DC plan sponsors, she added.
“What CAPSA forced us to do was look closely at whether that accountability was explicit or just simply understood. In practice, [the] roles were working well but some of the language blurred the line between oversight and execution.”
The updated guideline wasn’t a compliance exercise for CPP Investments, noted Lodyga. Instead, it functioned as a catalyst that raised the bar from knowing there’s existing, functioning compliance to showing exactly how it works. “The harder question was, ‘If this is the governance standard CAPSA is setting, are we confident that our global DC plans would stand up to the same level of scrutiny?’”
As well, the guideline didn’t introduce any new governance principles for CPP Investments but instead, it demanded explicit descriptions and a clearly outlined process, she said. “That shift matters because governance can exist in practice without always being clearly articulated.”
Read more coverage from the 2026 DC Plan Summit.