This article is for informational purposes only and does not constitute tax or financial advice. Consult a qualified accounting professional before making any tax or financial decisions.
Quick Answer
Most Canadian family trusts must file a T3 Trust Income Tax and Information Return with Schedule 15 (Beneficial Ownership Information) for tax years ending December 31, 2025, and the deadline was March 31, 2026. The Canada Revenue Agency confirmed that bare trusts did not have to file for the 2025 tax year, but certain bare trusts will need to file for tax years ending on or after December 31, 2026. Listed-trust exemptions in the Income Tax Act now cover trusts under $50,000 in assets, graduated rate estates, qualified disability trusts, and registered charities. Late or missing filings can trigger penalties of $25 per day to a maximum of $2,500, and a gross-negligence penalty of the greater of $2,500 or 5% of the highest fair market value of trust property in the year.
Why trust reporting suddenly got complicated
If you are a trustee, an executor, or simply someone with a joint bank account or an in-trust-for account for your child, you have probably read three different things this year about whether you need to file a T3 trust return. The rules genuinely changed three times between March 2024 and March 2026.
Here is what happened, in plain English. The federal government brought in expanded trust reporting in 2022 to take effect for trust year-ends starting December 31, 2023. Days before the 2024 filing deadline, the CRA paused the rules for bare trusts because the original definition was too broad. The government then released revised draft legislation in August 2024 and August 2025, tabled it as Bill C-15 on November 18, 2025, and the bill received Royal Assent on March 26, 2026. The rules are now law, with carve-outs the original 2022 rules did not have. For background, you can read our earlier note on potential relief for trust reporting requirements.
Trust Reporting Rules — What Changed When (2018–2027)
Eight milestones from the original 2018 budget proposal to the first mandatory bare-trust filings due in March 2027.
Quick start: pick your path
The fastest way through this article is to identify your situation, then read only the sections that apply.
You are most likely dealing with a bare trust. The 2025 deferral covered you, and many common arrangements now sit inside a Bill C-15 carve-out for 2026 onward.
Sole proprietorships are not trusts. You generally do not have a T3 obligation unless you also act as trustee for a separate arrangement.
A discretionary family trust, or a nominee corporation holding real estate for related parties, often must file. Read the comparison table and roadmap closely.
Estates that qualify as graduated rate estates have their own rules and are exempt from Schedule 15 even where a T3 is required.
If none of the four paths fits cleanly, your situation likely benefits from a 30-minute review with a tax professional. You can explore our tax and accounting services.
What counts as a “trust” for CRA reporting
A few short definitions will save you a lot of reading later. An express trust is any trust created on purpose, formally or informally, by someone (the settlor) transferring property to a trustee for the benefit of beneficiaries. A typical family trust set up by a lawyer is an express trust. A bare trust is a narrower type where the legal owner holds property strictly as agent for the beneficial owner and has no real decision-making power. Adding your adult child to your bank account, in many cases, creates a bare trust.
Three more terms appear constantly. The settlor is the person who put property into the trust. The beneficiary is the person or class of persons who benefit. The trustee is the person or company holding legal title and administering the trust. Schedule 15 simply asks the CRA to be told who all those people are.
2025 vs 2026 filing rules at a glance
The table below collapses three pages of CRA guidance into the answers most readers actually need. It maps six common trust types to whether a T3 and Schedule 15 are required for the 2025 and 2026 tax years.
| Trust type | 2025 T3 + Sch 15? | 2026 T3 + Sch 15? | Authority |
|---|---|---|---|
| Express trust with taxable income or a capital disposition | Yes (T3 + Sch 15) | Yes (T3 + Sch 15) | ITA s. 150(1) |
| Bare trust, no exemption applies | No (CRA deferral) | Yes (T3 + Sch 15) | Bill C-15, ITA s. 150(1.3) |
| Trust under $50,000 in assets (any asset type) | No | No (listed trust) | ITA s. 150(1.2) |
| In-trust-for account where all beneficiaries are also legal owners | No | No (carve-out) | Bill C-15 |
| Nominee corporation holding investment property for partners | No (CRA deferral) | Yes (T3 + Sch 15) | ITA s. 150(1.3) |
| Graduated rate estate | Yes (T3, Sch 15 exempt) | Yes (T3, Sch 15 exempt) | ITA s. 150(1.2) |
If your trust falls into more than one row, the most restrictive answer wins. For example, an express trust holding $40,000 in assets is still a listed trust under the small-trust exemption and is generally not required to file Schedule 15. Our practical T3 filing walkthrough for trustees covers the mechanics in more detail.
2025 vs 2026 Filing Requirements by Trust Type
Whether a T3 return with Schedule 15 is required, by trust type, for the two most recent tax years.
Step-by-step: filing your T3 and Schedule 15
- Confirm the trust’s tax year-endMost trusts use a December 31 year-end. Graduated rate estates can use a non-calendar year-end for up to 36 months after death. Get this date wrong and every other deadline shifts.
- Check the listed-trust and bare-trust exemptionsRun through the listed-trust list in s. 150(1.2) of the Income Tax Act. If your trust is a listed trust, the Schedule 15 disclosures generally do not apply. For bare trusts, check whether a Bill C-15 carve-out fits before doing anything else.
- Get a trust account numberIf the trust does not already have one, apply through the CRA’s online trust account number service. Without this number you cannot file a T3 electronically and will likely face avoidable delays.
- Gather Schedule 15 informationYou will need the full legal name, address, date of birth, jurisdiction of tax residence, and tax identification number for every reportable entity, including trustees, beneficiaries, settlors, and any protectors. Build this file early; chasing missing details is the most common reason trustees miss the 90-day window.
- File the T3 return on timeFile electronically through Trust EFILE where possible. Tax preparers filing more than five trust returns of the same type are required to file electronically. Our explainer on key T3 and T5013 deadlines covers the timing.
- Keep contemporaneous recordsThe CRA’s reassessment window for trust returns can run for years after filing. Keep the trust deed, every Schedule 15 entry, and any correspondence with beneficiaries in one place.
Bare trust scenarios: does yours need to file for 2026?
Five real-world scenarios cover most Canadian readers. Joint chequing account with a spouse where you both deposit, withdraw, and benefit is typically exempt because every legal owner is also a beneficiary. Adult child added to an aging parent’s bank account for help with bills is often exempt under the related-persons rule, although the facts of who actually benefits matter. Parent on title of an adult child’s principal residence to co-sign a mortgage is typically exempt where the property is or could be a principal residence of one of the legal owners.
A nominee corporation holding rental real estate for a partnership generally must file because the property is not anyone’s principal residence. A lawyer’s client-specific trust account may be exempt where the funds are cash only and stay below $250,000 throughout the year.
Where Common Trust Arrangements Land for the 2026 Tax Year
Illustrative share of typical Canadian arrangements landing in each outcome after applying ITA s. 150(1.2)–(1.3) and Bill C-15 carve-outs.
Common mistakes trustees make
Six mistakes account for most of the trust reporting penalties we see. Each one is fixable if you catch it early.
- →Assuming the bare-trust pause is permanent. The 2023, 2024, and 2025 deferrals are over for 2026 tax years, and many bare trusts now have a fresh filing obligation.
- →Missing the 90-day window because the trust does not use a December 31 year-end. Graduated rate estates and certain wound-up trusts have non-calendar year-ends.
- →Reporting only beneficiaries on Schedule 15 and forgetting settlors and protectors. Anyone who can override trustee decisions is a reportable entity.
- →Treating an in-trust-for account as informal. The legal-versus-beneficial split usually creates a bare trust even with no written deed.
- →Filing a T3 with the trust’s tax identification number but skipping enrolment for Trust EFILE. Paper returns above the threshold attract their own penalties.
- →Keeping no contemporaneous records of beneficial ownership, then scrambling to reconstruct details years later if the CRA reassesses.
Our overview of CRA compliance issues SMEs are watching in 2026 includes more detail on documentation expectations.
What happens if you file late or not at all
The two penalty regimes work together. A trustee who files late but cooperates with the CRA can typically expect the daily penalty only. A trustee whose conduct meets the legal test for gross negligence can be exposed to a far larger amount that scales with the size of the trust. Voluntary disclosure remains available where a filing has been missed and the conditions of the program are met. Our CRA audit checklist walks through the documentation that helps reduce that risk.
Trust Reporting Penalty Exposure by Filing Behaviour
Illustrative penalty exposure in Canadian dollars. Late-filing maxes out at $2,500. Gross-negligence scales with trust property value.
Frequently asked questions
Do I really have to file a T3 trust return for my family trust this year?
Is a joint bank account with my spouse considered a trust by the CRA?
What is Schedule 15 and what information do I have to put on it?
I added my adult child to my bank account, does that mean I have a bare trust?
What is the deadline to file a T3 return in Canada?
What happens if I miss the filing deadline or skip Schedule 15?
Are small family trusts under $50,000 still required to file?
Do these trust reporting rules work the same way in Quebec?
For broader planning context once your filing is in order, our note on creating a lasting legacy in family businesses is a useful next read.
Where ClearWealth fits in
Get a clear answer in 30 minutes
Trust reporting in Canada is genuinely complex, and the rules just changed for the third time in three years. The good news is that for most readers, the right answer is short and stable once a tax professional has looked at the facts. ClearWealth Accounting Advisors works with Ontario individuals, sole proprietors, and incorporated business owners on T3 filings, Schedule 15 reporting, and CRA disputes.
Book a ConsultationThis article is for informational purposes only and does not constitute tax or financial advice. Consult a qualified accounting professional before making any tax or financial decisions.
Sources & References
- Canada Revenue Agency — Enhanced reporting rules for trusts and bare trusts: Frequently asked questions · https://www.canada.ca/en/revenue-agency/services/tax/trust-administrators/t3-return/enhanced-reporting-rules-trusts-bare-trusts-faq.html
- Canada Revenue Agency — Filing a trust’s T3 return: What has changed · https://www.canada.ca/en/revenue-agency/services/tax/trust-administrators/t3-return/filing-trust-return/what-changed.html
- Canada Revenue Agency — Who should file a T3 return · https://www.canada.ca/en/revenue-agency/services/tax/trust-administrators/t3-return/filing-trust-return/who-should-file.html
- Canada Revenue Agency — Important updates to the trust reporting requirements for the 2025 taxation year · https://www.canada.ca/en/revenue-agency/news/newsroom/tax-tips/tax-tips-2026/important-updates-trust-reporting-requirements.html
- Canada Revenue Agency — T4013 T3 Trust Guide · https://www.canada.ca/en/revenue-agency/services/forms-publications/publications/t4013/t3-trust-guide.html
- Department of Justice — Income Tax Act, section 150 · https://laws-lois.justice.gc.ca/eng/acts/i-3.3/section-150.html
- Parliament of Canada — Bill C-15, An Act to implement certain provisions of the budget tabled in Parliament on November 4, 2025 · https://www.parl.ca/legisinfo/en/bill/45-1/c-15
