Resource Centre | TELUS Health

Transforming public sector employee benefits accounting

Written by TELUS Health | March 27, 2026


The Canadian public sector is preparing for a significant shift in how employee benefits are accounted for and reported. On March 3, 2026, the Public Sector Accounting Board (PSAB) released the new Section PS 3251 – Employee Benefits, marking a pivotal moment in public sector accounting standards for plan sponsors covered by the new standard. This new standard will replace the existing PS 3250 (Retirement Benefits) and PS 3255 (Post-employment Benefits, Compensated Absences and Termination Benefits), with an effective date of fiscal years beginning on or after April 1, 2029.

The shift to international standards principles

The new PS 3251 represents PSAB's strategic decision to align Canadian public sector accounting with International Public Sector Accounting Standards (IPSAS), specifically adapting IPSAS 39 principles with certain modifications to fit the Canadian environment. This alignment reflects a broader global trend toward harmonized accounting practices while maintaining flexibility for domestic considerations.

Some of the key changes that will impact public sector organizations who sponsor a defined benefit post-employment benefits plan or other long-term employee benefits plan include:

  • Changes to the discount rate basis
  • The method for recognition of gains and losses
  • Enhanced disclosure requirements
  • Changes to measuring plan assets
  • The attribution method for determining benefit obligations and service cost
  • The absence of an earlier measurement date

Key changes in discount rate guidance

One of the most significant changes in PS 3251 involves how organizations determine discount rates for calculating the present value of employee benefit obligations.

Under the existing PS 3250 and PS 3255 standards, discount rate guidance is minimal. Organizations typically use the expected return on plan assets for funded plans and the entity's cost of borrowing for unfunded plans.

PS 3251 has a more structured approach based on a plan's funding status, with the methodology differing based on whether the plan is considered “fully funded” or “underfunded”. Determining whether a plan is considered a fully funded or an underfunded plan will depend on various qualitative and quantitative factors. An example of a qualitative factor is if there are regulatory, legislative, or contractual requirements to fully fund the plan. An example of a quantitative factor is if a recent funding valuation demonstrates that the plan is fully funded.

For fully funded plans, discount rates will be based on the expected market-based return on plan assets. This rate will depend on the plan’s investment strategy and policy.

For underfunded plans, discount rates will make reference to market yields on government bonds, high-quality corporate bonds, or other financial instruments with cash flows matching expected benefit payments. The rate must reflect the time value of money without including actuarial, investment, or entity-specific credit risks. Professional judgment is required in selecting the appropriate financial instrument. The ability to reference different financial instruments may lead to a wide range of acceptable discount rates in practice, thereby complicating the comparison of plans across different organizations.

For underfunded plans, organizations that currently use the cost of borrowing may see higher or lower discount rates under the new standard, depending on how the entity’s cost of borrowing compares with the yields on the financial instruments used to determine the discount rate under PS 3251.

Elimination of deferral provisions: Immediate recognition of gains and losses

Perhaps the most transformative change in PS 3251 is the elimination of the deferral provisions that currently allow organizations to spread recognition of actuarial gains and losses over time.

Under the current approach for PS 3250 and PS 3255, actuarial gains and losses are deferred and amortized over the expected average remaining service life (EARSL) of plan members. This approach smooths the impact on annual financial results. Note that for certain event-driven plans that do not vest, the organization currently has a choice between immediate recognition or amortization of gains or losses in profit & loss under PS 3255.

Under the new approach for PS 3251, the standard requires immediate recognition in the balance sheet of all remeasurements of the net defined benefit liability or asset. This includes actuarial gains and losses (demographic or economic), returns on plan assets that differ from the expected returns based on the discount rate assumptions, and changes in the asset ceiling effect.

As plan experience differs from assumptions from year to year and assumptions change, immediate recognition of gains or losses can create significant volatility for organizations. However, this volatility will flow through as a remeasurement of the net defined benefit liability (asset) rather than in annual surplus or deficit (commonly referred to as profit & loss – P&L).

There are some exceptions to this as Other Long-Term Employee Benefits may still flow through the P&L on an immediate basis.

This change introduces greater balance sheet volatility but provides more stability in the P&L for post-employment benefits.

Enhanced disclosure requirements

PS 3251 significantly expands disclosure requirements to provide stakeholders with more comprehensive information about employee benefit plans and associated risks.

Some of the disclosure enhancements include:

  • Various plan characteristics and risks, including a description of the regulatory framework, funding requirements, investment risks, plan’s funded status, and support for key assumptions.
  • Breakdown of actuarial gains and losses remeasurements by demographic and economic assumption changes.
  • Fair value of assets by main asset class and details on any asset-liability matching strategies.
  • Various assumption sensitivity tests, duration of the obligation and future expected cash flows.

These enhanced disclosures provide greater transparency but also require more sophisticated analysis and documentation.

Changes to plan asset measurement

The new standard introduces important changes to how plan assets are measured and defined. The main change is that smoothing techniques to dampen volatility effects are no longer permitted.

Attribution period refinements

PS 3251 introduces a stricter definition of the period over which benefits can be attributed to employee service. The attribution period will cease when further service would lead to no material additional benefits (other than from future salary increases). Furthermore, the new standard could also delay the start of the attribution period to coincide with service eligibility.

For most pension plans, this change will not have an impact. However, for post-retirement health and dental plans, there are situations where further service beyond a specific eligibility age does not lead to material additional benefits. Also, if eligibility is age and service related, there would be a delayed start to the attribution. For example, in a post-retirement health and dental plan where benefit eligibility is at age 55 with 10 years of service, the attribution period would start at age 45 and go to age 55 under the new standard rather than start at hire and go to retirement age under the current standard. The shorter attribution period would impact benefit obligations and likely result in more volatile service costs. An analysis of this impact prior to first adoption will help organizations prepare for PS 3251.

Measurement date

The current standard allows an organization to use an earlier measurement date for the reporting date. For example, some organizations use a December 31st measurement date for a March 31st fiscal year-end. PS 3251 does not provide this option and therefore the measurement date must be the reporting date. An earlier measurement date allows results to be prepared based on earlier market information rather than waiting until the end of the fiscal year. The new standard will not allow for this practical advantage, which will require tighter coordination among various stakeholders at year-end.

Transition and implementation timeline

The transition date is for fiscal years beginning on or after April 1, 2029, with earlier adoption permitted. This means that the first impact will be on disclosures for March 31, 2030 (for organizations with a March 31st fiscal year-end).

Retroactive transition and a prior comparative year disclosure may be required subject to whether the cumulative impact of the new standard on prior periods can be reasonably determined. Cumulative unrecognized gains or losses may be recognized in the opening balance of the earliest comparative period presented in the financial statements in the year of adoption.

Early adoption considerations

While there are a few years until adoption is required, the option of early adoption should consider the following:

    • Organizations that place an importance on P&L stability may benefit from earlier adoption. However, the P&L stability results in balance sheet volatility from remeasurements of the net defined benefit liability (asset) at the end of the fiscal year.
    • Strategic timing of benefit negotiations before April 1, 2028 (the comparative period) may be beneficial, as unamortized gains and losses will no longer exist to offset past service costs resulting from any negotiated benefit plan changes.
    • Organizations with underfunded programs may see volatility in the discount rate.
    • Organizations with benefits impacted by the change in attribution methods may see an increase in the benefit obligations and/or service costs.

Strategic implications for public sector organizations

The transition to PS 3251 requires significant preparation and analysis:

    • Financial statement impact: Organizations should conduct in-depth analysis of how these changes will affect their financial statements, particularly regarding balance sheet volatility and P&L reporting.
    • Policy development: Organizations without formal funding policies should consider establishing clear documentation of their funding objectives and corrective action procedures when their plan is not fully funded.
    • Systems and processes: Enhanced disclosure requirements will necessitate updated systems, processes, and actuarial analyses.
    • Stakeholder communication: Organizations should prepare to explain the changes to stakeholders, particularly regarding increased volatility in balance sheets and potentially P&L for some plans.
    • Early adoption decision: Each organization should evaluate whether early adoption aligns with their financial reporting objectives and operational capabilities.

Looking ahead

The new PS 3251 represents a fundamental shift in how Canadian public sector organizations account for and report their employee benefits. While the changes introduce greater complexity and disclosure requirements, they also provide enhanced transparency and more closely align Canadian standards with international standards. Organizations should begin their transition planning now to ensure smooth implementation by the April 1, 2029 effective date.

This article has been authored by Darren Klorfine, Gavin Benjamin, Catherine Lai, and Timothy Gray.