What are the changes in a nutshell?
- As of March 5, 2026, the Canada Revenue Agency (CRA) issued guidance on Bill C-15 proposing updates to trust reporting rules for the 2025 taxation year.(canada.ca)
- Bare trusts will not be required to file a T3 Trust Income Tax & Information Return (including Schedule 15 – Beneficial Ownership Information) for 2025, unless the CRA directly requests it.(canada.ca)
- All other trusts, unless they meet certain exemptions, are required to file the T3 return with Schedule 15 for the tax year ending in 2025.(canada.ca)
What this means for trustees & tax professionals
| Trust Type | 2025 Tax Year Filing Obligation | What to Watch |
|---|---|---|
| Bare Trusts | Not required to file T3 with Schedule 15 in 2025 unless CRA requests | Plan ahead: these trusts may have the obligation from 2026 onwards(canada.ca) |
| Other Trusts | Must file T3 and Schedule 15, unless exempt | Make sure beneficiary/trustee info, beneficial ownership, settlors are captured accurately(canada.ca) |
Key deadlines & compliance points
- Filing deadline: T3 returns are due no later than 90 days after a trust’s tax year-end. For trusts with a December 31, 2025 year-end, that means a deadline of March 31, 2026.(canada.ca)
- Ensure accurate information for trustees, beneficiaries, settlors, and anyone who may override control or influence distributions. This includes identity, address, tax number, date of birth, residency.(canada.ca)
- If you are a bare trust trustee, monitor whether CRA requests filing; maintain up-to-date ownership records in case Schedule 15 is requested. Even if not required, good documentation avoids surprises.
Practical example
- Alice holds property in a bare trust benefiting her children. For 2025, she does not file a T3 with Schedule 15, unless asked by CRA.
- However, for 2026, she should expect to prepare and submit beneficiary/trustee data as required. If she has another trust (discretionary family trust) for which beneficiaries are not merely “agents,” she must file for that trust in 2025.
Actionable steps
- Review your trust structure — determine whether it's a bare trust, family trust, or other trust type.
- Gather precise ownership data — legal ownership vs beneficial ownership, identity, settlors, trustees, influence persons.
- Update internal processes — align systems to collect data allowing for Schedule 15 compliance.
- Consult legal/tax advisor if unsure whether trust meets exemption criteria.
- File correctly and on time — missing Schedule 15 when required can lead to penalties.
Take-away
These proposed changes strike a balance between providing smaller or passive trusts relief for 2025 and reinforcing transparency for the broader trust sector. Staying informed and preparing now will ensure smooth compliance once rules are in force.