Alberta Bill 11 and Your Group Benefits Plan: What to Ask Before Renewal
By Patrick Hardie — Safe Crest Insurance Inc., independent brokerage licensed in Alberta and BC
Bill 11 passed in Alberta, and many employers have only heard a headline about it. The headline is that the public plan is intended to pay after private coverage for some health costs. For an employer, the real question is what that does to the plan you already have, and to the renewal letter that arrives this year.
Earlier in my career I worked as an underwriter with a group benefits carrier. I will be plain about where this article stops. Some of this is confirmed. Some of it is not confirmed yet, and your carrier may still be working through it. Where that is the case, I will say so and tell you what to ask.
This is general information. I am a broker, not a lawyer. Please confirm any legal obligation with your own counsel.
What Bill 11 is
Bill 11 is the Health Statutes Amendment Act, 2025 (No. 2). It received royal assent on December 11, 2025. It amends the Alberta Health Care Insurance Act. The Government of Alberta page describes three changes relevant to employers.
1. Drug coverage coordination. The Government of Alberta lists these amendments as coming into force on October 1, 2026, a date that has now passed. The Government of Alberta describes the public plan as payor of last resort. In plain terms, it is intended to pay after private coverage. How that works in your contract depends on its wording.
2. Employees 65 and older. The page says the amendments are intended to protect older Albertans from losing employer-sponsored health benefits "solely due to age." As the government describes it, employers would not be able to terminate or reduce health benefit coverage for actively employed employees who are 65 and older. The government page does not give an in-force date for this piece.
3. Private health services. The amendments allow Alberta employers to offer employees access to private health services from a physician, through their health plans. That reads as a permission rather than an obligation. The page gives no in-force date for this piece.
How the payment order may affect group plans
Some group plans reduce or end certain benefits at a set age, and some coordination wording may assume public coverage applies first. Check your own contract.
This may affect how some plans are built and priced. I do not know whether or how it will change any one plan. Groups with different age profiles may see different results.
What the carrier notice says
Manulife, a large Canadian group carrier, has posted a notice about Alberta Bill 11 (posted June 4, 2026). I am using it as an example of how a carrier is reading the law. Other carriers may word things differently. These are the points from that notice:
The age rule for active employees covers drug and health benefits. It does not cover life insurance, disability, dental, travel, health care spending accounts, or lifestyle spending accounts.
Age restrictions may continue for retiree plans.
For people 65 and older, the public plan is expected to pay only after private coverage for prescription drugs, land ambulance (not air ambulance), clinical psychologist services, home nursing care, and chiropractic care.
The rules apply to private plans covering Alberta residents. They do not apply to groups or members outside Alberta.
Manulife says it will review the changes at the time of renewal.
Manulife also says that service list is what it expects, and that the final list may differ. Please treat that list as provisional until your own carrier confirms it in writing.
Manulife's notice says the changes may increase plan costs. Whether and by how much for any group is not yet known.
What is not confirmed yet
Several of these points are still open.
Cost. I have no figure for what this does to premiums, and I will not guess. A figure given before your carrier prices your group would be an estimate.
The final service list. See above. It may change.
Retiree plans. The carrier notice says age restrictions may continue. That is all I can say with confidence. If you sponsor retiree coverage, ask your carrier and your lawyer what applies to your plan.
Pricing for any pooling or stop-loss arrangements. If your plan has them, I have no confirmed information on how they will be treated. Ask your carrier.
Legal obligations. What an employer must do, and what is optional, is a legal question. I am not the right person to answer it. Your counsel is.
Questions to ask now, before your renewal arrives
Here are the questions I would put on the table. You do not need to answer them alone. Most of them are for your carrier or broker to answer.
Has the coordination of benefits wording in our policy contract changed? Coordination of benefits is the clause that says which plan pays first when more than one plan could cover the same expense. Ask whether the contract wording has been updated since October 1, 2026, or will be, and with what effective date.
How many of our active employees are 65 or older? Count them. Ask your counsel or carrier whether part-time staff on the plan are included. This tells you how exposed you are.
Does our plan text have age-based reductions or terminations? Some plans reduce or end certain benefits at 65 or 70. Read your actual plan booklet and contract. Ask your carrier which of those provisions it considers affected, and which it does not.
How is our carrier pricing this change at our renewal? Ask them to explain it in terms of your group, not the market in general.
Do we offer retiree coverage? If yes, ask what the carrier and your counsel say about it.
Do we have employees or dependants outside Alberta? The carrier notice says the rules apply to Alberta residents. A group with members across provinces needs the answer for each location.
Do we want to consider the private health services option? The government page reads as a permission rather than an obligation, with no in-force date given. If it interests you, ask the carrier whether it can administer private health services from a physician through the plan, and on what terms.
What is the effective date for each piece as it applies to our plan? The drug coverage coordination amendments are listed by the Government of Alberta as coming into force on October 1, 2026, which has now passed. Ask your carrier about the date for the age protection and whether it applies at your next renewal or sooner.
What about British Columbia?
Bill 11 is an Alberta law, and the Manulife notice says the rules apply to members residing in Alberta. A group with employees only in BC would not be expected to be directly affected. Confirm with your carrier. If you have a group that covers employees in more than one province, the Alberta residents on your plan may be affected, and ask your carrier how the plan treats members in each province.
How employers can approach this
Some employers start by gathering their headcount of employees 65 and older, their plan booklet and contract, and their renewal date, then sending written questions to their carrier or broker and asking for written answers. Asking before the renewal number arrives gives more time to review it. Renewal is also when plan design and claims experience are normally reviewed. Any plan change would need to be considered against your contract and any legal obligations, with your own counsel.
Your Bill 11 questions, answered
What is Alberta Bill 11?
It is the Health Statutes Amendment Act, 2025 (No. 2), which received royal assent on December 11, 2025. It amends the Alberta Health Care Insurance Act. The Government of Alberta describes the public plan as payor of last resort for drug coverage, and the bill addresses employer health benefits for actively employed people 65 and older.
When do the drug coverage changes take effect?
The Government of Alberta lists the drug coverage coordination amendments as coming into force on October 1, 2026, which has now passed. The government page does not give an in-force date for the age protection or the private health services piece. Ask your carrier about your plan's effective dates.
Does the age rule apply to all of my benefits?
Not according to the Manulife notice. It says the rule for active employees covers drug and health benefits, and does not cover life, disability, dental, travel, health care spending accounts, or lifestyle spending accounts. Confirm the position of your own carrier.
Will my premiums go up?
I do not know, and no general answer applies to every group. Manulife has said it will review the changes at renewal, and the impact will depend on each group. Manulife's notice says the changes may increase plan costs. Whether and by how much for any group is not yet known. Ask your carrier how it is pricing the change for your group.
Does Bill 11 affect my retiree plan?
The Manulife notice says age restrictions may continue for retiree plans. That is as far as I can go. If you have retiree coverage, confirm what applies with your carrier and your own legal counsel.
Do I have to offer private health services through my plan?
According to the Government of Alberta, the amendments allow Alberta employers to offer employees access to private health services from a physician, through their health plans. That reads as a permission rather than an obligation, and the page gives no in-force date. If you are interested, ask your carrier whether and how it can be set up.
Talk it through before your renewal
If you would like a second set of eyes on the questions above, or on your renewal when it arrives, I am glad to help. I will look at your plan wording, your headcount, and what your carrier has told you, with no obligation.
Book a time to talk. Prefer to write first? Send a message.
This article is general education, not legal advice and not a recommendation for your specific plan. It is based on information from the Government of Alberta and a Manulife carrier notice, both current as of October 22, 2026. The details may change, and other carriers may read the law differently. Renewal pricing impact depends on each group, and no outcome is guaranteed. Please confirm any legal obligation with your own counsel. Safe Crest Insurance Inc. is not affiliated with the Government of Alberta or Manulife. Safe Crest is typically paid by insurers through commissions or fees. Patrick Hardie is licensed to sell insurance in Alberta (P/S - 2141086-11464417-2025) and British Columbia (LIC-2026-0063790) through Safe Crest Insurance Inc., an independent brokerage not affiliated with any single insurer.
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