Did my Will Just Revoke My Beneficiary Designations in my RSP and TFSA?
Ian Keay
September 25, 2026
Clients must consider their beneficiary designations.
A Will almost always begins with a clause that revokes earlier Wills. Did it also cancel the beneficiary designations previously made on RRSPs, RRIFs, TFSAs and similar plans? Here’s how that works in Ontario:
The Ontario Court of Appeal considered this issue in Alger v. Crumb, 2023 ONCA 209. The case confirms that a general revocation clause in a Will does not necessarily revoke beneficiary designations previously made directly with a financial institution. The wording of Ontario's Succession Law Reform Act (the "SLRA") requires something more specific.
Beneficiary Designations Operate Outside the Will
Many financial products allow the account holder to name a beneficiary who will receive the proceeds following the account holder's death. Common examples include:
- RRSPs;
- RRIFs;
- TFSAs; and
- certain pension or other benefit plans.
A beneficiary designation may be made directly through the financial institution. It can also, in appropriate circumstances, be made by Will. The SLRA specifically permits beneficiary designations and their revocation by either method. The potential problem arises when a person makes a beneficiary designation directly with the financial institution and later signs a Will containing different estate-distribution provisions. Does the later Will cancel the earlier designation?
Not necessarily.
What Happened in Alger v. Crumb?
Theresa Crumb had four children. Before her death, she designated all four children as equal beneficiaries under her RRIF and TFSA accounts held at Scotiabank. She later signed a Will. Under her Will, two of the children received specific $20,000 bequests, while the residue of the estate was left to the other two children. Her Will also contained a conventional general revocation clause intended to revoke earlier Wills and testamentary dispositions.
Note that her Will did not align with the designations she made at Scotiabank. This difference mattered.
If the RRIF and TFSA beneficiary designations remained effective, all four children would share equally in those accounts. If the Will had revoked those designations, the account proceeds could instead fall into the estate and be distributed in accordance with the Will. The estate trustees argued that the Will's general revocation clause was broad enough to cancel the RRIF and TFSA designations.
The Court disagreed.
Section 52 of the Succession Law Reform Act
Section 52(1) of the SLRA deals directly with this issue. Where a beneficiary designation was made by an instrument - for example, documentation completed with a financial institution - a revocation contained in a Will is effective only where the revocation expressly relates to the designation, either generally or specifically.
That word "expressly" was important in Alger.
The Court accepted that a beneficiary designation can constitute a testamentary disposition. However, simply revoking all previous "testamentary dispositions" was not enough. The Will still had to expressly refer to beneficiary designations in the manner required by Section 52(1). The Court therefore concluded that the existing RRIF and TFSA beneficiary designations had not been revoked by the general revocation clause in her Will.
General Language Is Not Necessarily Enough
The distinction is fairly technical but has significant practical consequences. A person might sign a Will saying, in substance:
I revoke all previous Wills and testamentary dispositions.
That sounds extremely broad. Nevertheless, Alger confirms that broad language describing a larger category of testamentary dispositions does not necessarily satisfy the statutory requirement to expressly address an existing beneficiary designation. The Will does not necessarily have to identify every account number and every financial institution. Section 52(1) allows the designation to be addressed generally or specifically. What matters is that the revocation expressly relates to the beneficiary designation itself.
Why Does This Matter for Estate Planning?
A person's Will is only one component of their estate plan. A significant amount of wealth may pass outside the estate through beneficiary designations. RRSPs, RRIFs, TFSAs and other plans can therefore produce a very different distribution from the one that appears on the face of the Will.
Consider a simple example:
A parent has three children. The parent’s Will divides the estate equally among all three. Years earlier, however, the parent designated only one child as beneficiary of a substantial RRIF. Unless that designation is properly changed or revoked, the RRIF would be transferred directly to the designated child notwithstanding the equal division provided for in the Will. The reverse problem can also arise. A person may deliberately change their Will but fail to consider beneficiary designations made years earlier. The resulting estate distribution may be very different from what the family expected.
Review the Will and the Beneficiary Designations Together
The practical lesson from Alger is not merely that revocation clauses require careful drafting. It is that beneficiary designations should be reviewed as part of the overall estate plan. When preparing or updating a Will, the client should consider:
- what registered plans and other beneficiary-designated assets they own;
- who is currently designated as beneficiary;
- whether those designations remain consistent with the estate plan;
- whether any designation should remain in place;
- whether a designation should be changed directly with the financial institution; and
- whether the Will is intended to make or revoke any beneficiary designation.
These issues become particularly important following marriage, separation, death of a beneficiary, family estrangement or a significant change in the value of a registered account.
The Bottom Line
Alger v. Crumb illustrates how a few words in a Will can have significant financial consequences. A general clause revoking prior Wills and testamentary dispositions does not, by itself, necessarily revoke beneficiary designations previously made on a RRIF, TFSA or similar plan. Under Section 52(1) of Ontario's Succession Law Reform Act, the Will must expressly relate to the beneficiary designation for that type of revocation to be effective.
Estate planning therefore requires more than reviewing the Will in isolation. Beneficiary designations and the Will should be considered together so that the assets passing outside the estate do not unintentionally undermine the intended estate plan.
Ian Keay
