The federal government invited submissions until Aug. 28 ahead of its budget 2025 ­ -- the first under Prime Minister Mark Carney -- to be tabled unusually late this year, in October.

CLHIA's submission draws attention to recent taxation changes that it says put Canadian firms at a disadvantage:

CLHIA also advocates for a harmonized licensing system for life and health insurance agents across provinces, and harmonized reporting requirements for cyber incidents to reduce the administrative burden for firms. The Canadian Council of Insurance Regulators (CCIR) published a position paper on the latter in May, outlining 11 recommendations for its members.

It also supports pension innovation, specifically in the form of VPLAs. While federal legislation was passed in 2021 dealing with VPLAs, which would provide payments based on the investment performance of the underlying annuities fund and on the mortality experience of annuitants, there has been little movement since. CLHIA advocates for a VPLA framework that will allow funds outside of defined contribution and pooled pension plans -- such as RRSPs, RRIFs and LIRAs -- to participate.

The insurance association also has an eye on investing in Canadian infrastructure, which the Office of the Superintendent of Financial Institutions' recent decision to reduce capital charges on such investment is meant to encourage. It notes Canadian insurers have already invested $60 billion in domestic infrastructure.

"We recommend the government leverage our industry's investment capacity and expertise, through partnerships, to expand and accelerate long-term financing structures, create a framework to develop policies which attract private capital and remove regulatory inefficiencies," the association submission reads.