Compliance
Trust & Bare Trust Reporting Changes in 2025: What Trustees Must Know
Significant changes in 2025 trust reporting—especially for bare trusts—and legal shifts impacting Schedule 15 mean accurate compliance is more important than ever.
By NomadicTax Research Team • 5 min read • April 11, 2026
## Overview of 2025 Trust Reporting Changes
Changes proposed in **Bill C-15** (implementing certain parts of Budget 2025) bring clarity to who must file the T3 Trust Income Tax Return and when, especially concerning **bare trusts** and reporting of **beneficial ownership** via Schedule 15. ([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 vs Other Trusts
- **Bare trusts** hold legal title only; beneficiaries have the full equitable ownership and control.
- Under the new rules, **bare trusts are exempt from filing Schedule 15** for 2025 taxation year, unless subjected to specific CRA demands. But starting with trust tax years ending in 2026, many bare trusts may no longer avoid reporting. ([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))
- **Other trusts** (i.e. family trusts, discretionary trusts) now are required to file T3 return **including Schedule 15** for 2025 if conditions met. Deadline: 90 days after tax year end (March 31, 2026 for calendar year-end trusts). ([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 Obligations for Trustees
- **Determine whether your trust is a bare trust**: if yes, often exempt for 2025; avoid claiming exemptions without confirming.
- **Ensure Schedule 15 accuracy**: list all beneficial owners, their addresses, dates of birth/tax IDs. Residential status matters.
- **Keep tax year-end dates in view**: for 2025 trust year‐end (e.g. December 31), file by **March 31, 2026** if Schedule 15 applies. For trusts ending later in year, count 90 days out. ([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))
- **Document governance**: clarify trust deed terms, beneficiary powers, control mechanisms—they influence beneficial ownership and whether exemptions apply.
## Examples
- **Family trust** that awards income to children and has discretionary power to change beneficiaries: must file with Schedule 15 for 2025, with complete information.
- **Bare trust** set up solely to hold property with equitable owners identifiable: exempt for 2025 but plan for 2026 where Schedule 15 may be required.
## Common Missteps to Avoid
- Assuming bare trust status automatically means no filing—CRA’s notice says “may be required.” Always check conditions. ([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))
- Late filing leading to penalties; deadlines are strict.
- Incomplete beneficial ownership disclosures—CRA may request further info if missing.
- Ignoring updates: CRA T4013 Trust Guide and T3 returns & schedules have been updated to reflect the changes. Use the current forms. ([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))
## Actionable Takeaways
- Review trust structures now; prepare records ahead of 2026 changes.
- Use the updated **Trust Guide 2025** from CRA and follow new instructions for Schedule 15.
- If unsure whether bare trust or not, consult legal/tax professional.
- For multi-jurisdictional trusts, consider impact of beneficial ownership laws in foreign jurisdiction too.
**Bottom line**: The era of blurred trust reporting is ending. Those managing trusts need clarity, accuracy, and timely action to avoid costly missteps.
*Author: NomadicTax Research Team*