Overview
The Canada Revenue Agency (CRA) has introduced significant changes to bare trust reporting 2026, impacting many Canadian businesses and individuals. These updates aim to enhance transparency and combat financial crime, requiring more detailed disclosure than ever before.
Understanding these new obligations is crucial for compliance and avoiding penalties, as the CRA expands its reach to include trusts previously exempt from reporting requirements.
- New Requirements: Discover the expanded scope of reporting, including who is now required to file a T3 Income Tax and Information Return, even for trusts with no income or tax payable, as part of CRA updates.
- Key Changes: Learn about the specific modifications to the T3 Trust Income Tax and Information Return, particularly the new Schedule 15, Beneficial Ownership Information of a Trust, which mandates detailed information on all trustees, beneficiaries, settlors, and controlling persons, as detailed in key changes.
- Exemptions and Penalties: Identify which trusts are exempt from these new reporting rules and understand the severe penalties for non-compliance, including late-filing penalties and gross negligence penalties.
- Compliance Strategies: Gain practical tips for navigating the new reporting landscape, including advice on identifying bare trust arrangements, gathering necessary information, and ensuring timely submission to the CRA.
Bare Trust Reporting 2026: What Canadian Businesses Must Know
In a previous article, we outlined the proposed changes to bare trust reporting and the uncertainty surrounding filing obligations. The CRA has since released updated guidance, and the rules are now more defined in 2026.
What’s New: CRA Bare Trust Reporting Updates for 2026
- No filing required for bare trusts for the 2025 tax year
The CRA has confirmed that bare trusts are not expected to file a T3 return or Schedule 15 for taxation years ending in 2025.
- Filing obligations return for 2026 tax years
Certain bare trusts will need to file for taxation years ending on or after December 31, 2026, subject to the passing of Bill C‑15.
- Legislative updates narrowing who must file
Proposed changes include exemption thresholds such as:
- Trusts with total fair market value (FMV) under $50,000
- Trusts holding only specified “low‑risk” assets with FMV under $250,000, if additional conditions are met
Find more information here.
CRA Bare Trust Reporting Updates for 2026: Key Changes
- Determine whether your arrangement is a bare trust
Common scenarios highlighted by tax professionals include title‑only arrangements, co‑signed mortgages, and joint accounts created for convenience, relationships where legal and beneficial ownership differ.
- Use 2025 to organize information
Even with no filing required for 2025, you should begin gathering:
- Beneficial ownership details
- Dates and purpose of the arrangement
- Documentation showing who funded or controls the asset
- Review whether you qualify for exemptions
The proposed FMV‑based thresholds may exclude your arrangement from needing to file in 2026. Early assessment will prevent surprises.
Practical Tips for Bare Trust Reporting in 2026
Bare trust rules continue to shift, and it can be difficult to know whether your arrangement will require filing in 2026. KWB helps business owners to simplify your accounting, improve your profit, and achieve your goals. Book an introductory meeting here to learn more about becoming a client.