Compliance
Compliance Spotlight: Trusts & New Reporting Rules in Canada for 2025 Tax Year
Trust holders, trustees and beneficiaries need to know new CRA reporting requirements sweeping for the 2025 taxation year. Missing Schedule 15 or trust-return deadlines could result in penalties.
By NomadicTax Research Team • 5-8 min read • March 17, 2026
## What’s New for Trusts in 2025
Effective for the **2025 taxation year**, Canada Revenue Agency (CRA) requires more robust reporting for trusts:
* All affected trusts must file a **T3 Trust Income Tax and Information Return**, including **Schedule 15 – Beneficial Ownership Information** (unless certain conditions apply or unless CRA specifically requests).([canada.ca](https://www.canada.ca/en/revenue-agency/news/e-services/canada-revenue-electronic-mailing-lists/businesses-tax-information-newsletters/businesses-newsletter-2025-02-27.html?utm_source=openai))
* Bare trusts are exempt from filing T3 and Schedule 15 for the 2023 and 2024 years, unless directly requested by the CRA. But that exemption no longer applies for all trusts in 2025.([canada.ca](https://www.canada.ca/en/revenue-agency/news/e-services/canada-revenue-electronic-mailing-lists/businesses-tax-information-newsletters/businesses-newsletter-2025-02-27.html?utm_source=openai))
## Who Is Affected
* Inter vivos and inter-vivos trusts (living trusts) with assets or activity in Canada.
* Trusts owning Canadian property, earning Canadian-source income, or managed in Canada.
* Trustees, beneficiaries, or trust creators involved in trusts with foreign elements or complexity.
## Practical Steps & Examples
| Scenario | Action Needed | Consequence of Non-Compliance |
|—|—|—|
| You are trustee of family trust with rental income in BC | Prepare a full T3 return; include Schedule 15, identifying all beneficial owners (even ancestors or spouses under certain definitions) | Penalties, missed informational return obligations, audit risk |
| You hold a bare trust for relatives with minimal assets for 2023-24 | Possibly exempt for 2023-2024, but must monitor if CRA requires filing; for 2025, you likely need to file unless special exemption applies | Risk of having to file late or respond to CRA demand |
## What to Include on Schedule 15
* Full legal name and address of **every beneficial owner** (as defined by the legislation). Ownership includes direct or indirect, legal or de facto control or interest.
* Nature of interest (percentage share or rights). Even if ownership is minimal, **control or influence** matters.
* If ownership is held via corporations, partnerships, or other trusts, trace through layers; provide full chain per rules.
## Deadlines & Penalties
* Tax year-end trust returns (T3) due **90 days** after trust year-end. For calendar-year trusts, that’s **March 31**.([canada.ca](https://www.canada.ca/en/revenue-agency/news/e-services/canada-revenue-electronic-mailing-lists/businesses-tax-information-newsletters/businesses-newsletter-2025-02-27.html?utm_source=openai))
* Filing Schedule 15: included with T3. Late filings can generate penalties under the Trust Reporting obligations. CRA has widened compliance enforcement. No longer the previous moratorium for bare trusts beyond 2024.([canada.ca](https://www.canada.ca/en/revenue-agency/news/e-services/canada-revenue-electronic-mailing-lists/businesses-tax-information-newsletters/businesses-newsletter-2025-02-27.html?utm_source=openai))
## Tips to Stay Compliant
- Keep trust records clean: register beneficial owners early, track changes in ownership, control or beneficiaries.
- Use experienced tax counsel to navigate complex inter-trust or corporate ownership chains.
- Integrate trust-reporting calendar into your annual tax-planning schedule to avoid missed deadlines.
- When in doubt about exemption status (e.g. bare trusts, low-asset trusts), document reasoning and correspondence with CRA.
## Why It Matters
Trust transparency has become a priority for CRA globally, as Canada strengthens its anti-avoidance and beneficial ownership reporting rules. Missing or sloppy reporting opens up risks from penalties, audits, and reputational damage—especially for high-net-worth or complex trust structures.
These new rules for 2025 mean **no more assumption of exemption** for many trusts. Getting ahead will save headaches tomorrow.