Compliance
Navigating Canada’s Updated Trust Reporting Requirements (2025 Tax Year)
Trustees and beneficiaries should understand the proposed changes under Bill C-15 impacting filing obligations, beneficial ownership disclosure, and deadlines for T3 trusts.
By NomadicTax Research Team • 5-8 min read • March 20, 2026
## What’s Changing and Who’s Affected
- **Bill C-15**, tabled in association with Budget 2025, introduces amendments that affect how trusts must file their **T3 Trust Income Tax and Information Return**, especially regarding **Schedule 15** (Beneficial Ownership Information). ([canada.ca](https://www.canada.ca/content/canadasite/en/revenue-agency/news/newsroom/tax-tips/tax-tips-2026/important-updates-trust-reporting-requirements.html?utm_source=openai))
- Bare trusts are **not required** to file Schedule 15 for the 2025 taxation year, but many **other trusts** will need to file their T3 returns including Schedule 15 if they are express trusts or otherwise don’t qualify as exempt. ([canada.ca](https://www.canada.ca/content/canadasite/en/revenue-agency/news/newsroom/tax-tips/tax-tips-2026/important-updates-trust-reporting-requirements.html?utm_source=openai))
## Deadlines and Compliance
- For most trusts with a **December 31, 2025** fiscal year-end, the new filing deadline remains **March 31, 2026** for T3 returns including Schedule 15 where required. ([canada.ca](https://www.canada.ca/content/canadasite/en/revenue-agency/news/newsroom/tax-tips/tax-tips-2026/important-updates-trust-reporting-requirements.html?utm_source=openai))
- Penalties may apply if a trust fails to file on time when Schedule 15 is required. Trustees should confirm filing requirements annually. ([canada.ca](https://www.canada.ca/content/canadasite/en/revenue-agency/news/newsroom/tax-tips/tax-tips-2026/important-updates-trust-reporting-requirements.html?utm_source=openai))
## Practical Examples
- A family trust that is not a bare trust, with a December 31 year-end, must file both the T3 return and Schedule 15 by March 31, 2026. Because it is not bare trust, it doesn't qualify for that short-term exception.
- A bare trust holding property solely on behalf of beneficiaries, with no discretionary powers, is exempt from filing Schedule 15 for tax year ending December 31, 2025—but should prepare for possible obligations in year ending December 31, 2026.
## Actionable Insights
- Trust administrators should review trust agreements now to determine whether their trust is a “bare trust” and whether it has any obligation under these new rules.
- Keep detailed records of **beneficial owners**, and ensure documents are ready to satisfy Schedule 15 requirements if needed.
- Consider engaging legal or tax counsel to understand whether your trust’s activities or characteristics cause it to fall inside or outside exemptions.
- Update tax-preparation systems and software to reflect the proposed changes in the guides and T4013 as soon as they are published.
## Why It Matters
These changes reflect Canada’s increasing focus on trust transparency and preventing the misuse of trusts for tax avoidance. For trusts previously operating without disclosure obligations, the changes bring new reporting responsibilities. That means utility for tax planning but also stronger penalties for non-compliance.