— Quick answer for trustees facing the March 31 deadline
Schedule 15 of the T3 trust return requires trustees to disclose, for every trustee, settlor, beneficiary, and controlling person of the trust, five data points: full legal name, current address, date of birth (for individuals), jurisdiction of tax residence, and tax identification number. For trusts with a December 31, 2025 year-end, the filing deadline is March 31, 2026. Most resident express trusts that are not listed trusts must file, but Bill C-15 (Royal Assent March 26, 2026) broadened exemptions for trusts under $50,000 and certain family trusts under $250,000 holding only low-risk assets. Late filing triggers a $25-per-day penalty (minimum $100, maximum $2,500), and gross-negligence failures trigger an additional penalty of the greater of $2,500 or 5% of the highest fair market value of trust property held during the year.
— Why Schedule 15 caught Canadian trustees off-guard
If you only just learned you may have a Schedule 15 obligation, you are not alone. When the enhanced trust reporting rules first applied for the 2023 tax year, thousands of Ontario families discovered they were trustees of arrangements they had never thought of as trusts — the joint bank account with an aging parent, the property in a nominee corporation, the child added to a mortgage.
In late 2025 the federal government tabled the new trust reporting rules in Canada as part of Bill C-15. The bill received Royal Assent on March 26, 2026, broadening exemptions for many small and family trusts but keeping the disclosure regime in place. The rules are now settled.
— Pick your path
Schedule 15 filing decision matrix — 2025 tax year
Which Ontario trustee profiles must file Schedule 15? Outcome by scenario, under post-Bill-C-15 rules.
— What counts as a reportable entity on Schedule 15
Trustees are the people or institutions holding legal title to the trust property. If you signed a trust deed years ago and forgot you were a trustee, you are still on the list.
Settlors are people or partnerships who transferred property to the trust. For tax years ending on or after December 31, 2024, the definition covers anyone who has directly or indirectly transferred property to the trust at any time. Narrow carve-outs exist for genuinely arm’s-length transfers.
Beneficiaries are the people for whose benefit the trust exists. This includes contingent beneficiaries — future children, grandchildren, and their spouses — not just those who received money this year. The CRA has confirmed contingent beneficiaries must be reported regardless of how remote their interest.
Controlling persons — sometimes called protectors or appointers — are people who can influence trustee decisions about distributing income or capital. If your deed gives anyone a veto, a power to appoint or remove trustees, or a power to direct distributions, that person is a controlling person.
— The five data points you must disclose for every person
For each reportable entity, Schedule 15 Part B requires five specific data points. Missing one creates a filing risk.
Full legal name. Use the name on the person’s passport or government ID, not the name they go by. “Bill Smith” is not enough if the SIN is registered to “William James Smith.”
Current address. Where the person lives now — not where they lived when the trust was created.
Date of birth. Required for individuals only. For corporate, trust, or partnership entities, this field is left blank.
Jurisdiction of tax residence. For most Ontario reportable entities this is “Canada,” but an adult child working abroad may have a different tax residence than parents assume.
Tax identification number. SIN for Canadian individuals, business number for Canadian corporations, trust account number for other trusts, and the foreign-jurisdiction identification number for non-residents.
If a beneficiary cannot be identified — the classic example is unborn children and grandchildren — complete Part C of Schedule 15 with a sufficiently detailed class description, and document the reasonable efforts you made to identify them.
Disclosure fields required per reportable entity type
Schedule 15 Part B asks for the same five data points whether the entity is a trustee, settlor, or beneficiary.
— Do you have to file? Side-by-side comparison
| Scenario | T3 return | Schedule 15 | Filing basis |
|---|---|---|---|
| Family trust holding private-company shares | Required | Required | Private-company shares disqualify from listed-trust exception. Deadline March 31, 2026. |
| Small family trust under $250K (cash and GICs only) | May be required | Not required | May qualify for the expanded family-trust exception under Bill C-15 if all beneficiaries are related to all trustees. |
| Bare trust on principal residence between spouses | Not expected for 2025 | Not required for 2025 | Mandatory bare-trust filing begins for taxation years ending on or after December 31, 2026. |
— Your step-by-step roadmap from trust deed to filed return
If Schedule 15 applies, the path from confusion to a filed return is shorter than it looks.
- 1Locate every governing documentThe trust deed is essential, but so are side letters naming a protector or controlling person.
- 2Identify every reportable entityWalk through the four classes — trustees, settlors, beneficiaries (including contingent), and controlling persons. List everyone; narrow later if exemptions apply.
- 3Collect the five data pointsBuild a five-column template and request the information directly. The SIN is a legal requirement, not optional.
- 4Determine whether the trust is a listed trustCategories are in section 150(1.2) of the Income Tax Act, including Bill C-15 exceptions for trusts under $50,000 and family trusts under $250,000 in low-risk assets.
- 5Get a trust account numberApply through CRA My Trust Account if you do not have one. This CRA My Business Account walkthrough covers the same login flow.
- 6Complete the schedulePart A confirms whether this is a new filing. Part B is one copy per reportable entity. Part C handles unknown beneficiaries.
- 7File on time, in the prescribed formatThe CRA accepts Schedule 15 only on the prescribed form — not as Excel, PDF, or XML exports.
Schedule 15 penalty escalation — cost of getting it wrong
Late-filing penalties cap at $2,500. Gross-negligence penalties scale to 5% of trust property value.
— Common mistakes Ontario trustees make on Schedule 15
The same handful of mistakes account for most Schedule 15 problems we see during filing season.
- →Assuming contingent beneficiaries do not need to be reported. They do, regardless of how remote their interest.
- →Forgetting to disclose a protector or appointer named in the trust deed. Anyone with power to override or direct trustee decisions is a controlling person.
- →Treating the trust as a bare trust without confirming the legal characterisation. The bare-trust filing relief applies only to genuine bare trusts — most discretionary family trusts are not bare trusts.
- →Submitting Schedule 15 data in a non-prescribed format. The CRA does not accept Excel, PDF, or XML exports.
- →Selecting “no changes” in Part A without checking the previous year’s Notice of Assessment. If the CRA did not retain prior-year information, that selection submits nothing.
- →Missing the SIN of an adult-child or sibling beneficiary. Request it months before the March 31 deadline, not days before.
- →Filing a T3 return without Schedule 15 when it is required. Review the CRA audit preparation checklist if you are uncertain about the trigger.
— Frequently asked questions about Schedule 15
Schedule 15 rule evolution — 2023 to 2027
When each phase of the trust reporting regime applies. Hover or tap any milestone for details.
Do I really need my adult kids’ social insurance numbers to file Schedule 15 for our family trust?
Yes, in most cases. If your adult children are beneficiaries — and they typically are, even as contingent beneficiaries — the SIN is one of the five required data points on Schedule 15 Part B. Without it, the filing is incomplete and can trigger a penalty.
What happens if I cannot find a beneficiary’s date of birth or tax ID before the March 31 deadline?
If the identity is genuinely unknown (an unborn grandchild, for example), complete Part C of Schedule 15 with a class description. If the beneficiary is known but unreachable, document the reasonable efforts you made and consider filing on time with the information you have.
My in-laws transferred $100,000 to our family trust years ago — do I have to list them as settlors?
Probably yes. For tax years ending on or after December 31, 2024, the settlor definition covers anyone who directly or indirectly transferred property to the trust at any time. Narrow exceptions exist for arm’s-length transfers, but in-laws are not generally arm’s length.
Our trust deed names my brother as a protector with veto power over distributions — does he need to be on Schedule 15?
Yes. A protector with the ability to influence trustee decisions about appointing income or capital is a controlling person, and must be disclosed with the same five data points as every other reportable entity.
I added my adult son to the title of my Toronto home so he can help with the mortgage — do I have a bare trust I need to report?
You may have a bare trust, but for the 2025 tax year the CRA does not expect bare trusts to file Schedule 15. Mandatory filing begins for taxation years ending on or after December 31, 2026.
If I miss the March 31, 2026 deadline by two weeks, what will the CRA actually charge me?
The late-filing penalty is $25 per day, with a minimum of $100 and a maximum of $2,500 — so two weeks late typically means a $350 penalty. Knowing or grossly negligent failures attract an additional penalty of the greater of $2,500 or 5% of the highest fair market value of trust property held during the year.
Get Schedule 15 right the first time
Schedule 15 is wider than most trustees expect. If you are unsure whether it applies to your trust, book a consultation with ClearWealth. We work with Ontario trustees through every step of T3 and Schedule 15 filing.
Book a ConsultationSources and references
- →Canada Revenue Agency — T3 Trust Guide (T4013), 2025 edition
- →Canada Revenue Agency — Enhanced reporting rules for trusts and bare trusts: FAQ
- →Canada Revenue Agency — Filing a trust’s T3 return: Getting ready to file
- →Canada Revenue Agency — T3SCH15 Beneficial Ownership Information of a Trust (form)
- →Canada Revenue Agency — Important updates to trust reporting requirements for the 2025 taxation year
- →Canada Revenue Agency — Filing a trust’s T3 return: Who should file
- →Bill C-15 — An Act to implement certain provisions of the budget (Royal Assent March 26, 2026)
- →Income Tax Act — section 150 (filing) and sections 162/163 (penalties)
