CRA Trust Reporting 2026: Deadline and Compliance Guide

If you’re a trustee of any Canadian trust—family trust or alter ego trust—you have exactly 12 days until a critical CRA deadline that many trustees still don’t know exists.

March 31, 2026 is the filing deadline for 2025 T3 Trust Income Tax and Information Returns, and for the second year running, CRA’s expanded beneficial ownership reporting requirements under Schedule 15 are creating confusion, compliance burdens, and potential penalties for unprepared trustees.

Here’s what you need to know, what’s changed since last year’s inaugural Schedule 15 filings, and how to avoid the $2,500+ penalties for non-compliance.

Bare trust update (verified September 2, 2026): Bare trusts are not part of this year’s mandatory filing group. CRA has confirmed that bare trusts are exempt from filing a T3 return and Schedule 15 for the 2023, 2024, and 2025 tax years. The bare-trust filing requirement resumes only for taxation years ending on or after December 31, 2026 — meaning the first mandatory bare-trust T3/Schedule 15 filings will be due March 31, 2027. Everything below about the March 31, 2026 deadline applies to family trusts, alter ego trusts, and other non-exempt express trusts — not to bare trusts.

What Changed in 2023 (And Why It Still Matters in 2026)

Prior to the 2023 tax year, many trusts flew under CRA’s radar. Bare trusts—where the trustee holds legal title but has no independent powers—generally didn’t need to file T3 returns. Family trusts with minimal activity often skated by without filing. Estate trusts sometimes went years without formal reporting.

That ended on December 31, 2023.

New subsection 150(1.2) of the Income Tax Act imposed enhanced T3 filing requirements, effective for taxation years ending on or after December 31, 2023, on virtually all express trusts. Bare trusts were originally swept into that expanded definition, but CRA has since granted bare trusts a standing administrative exemption from the T3/Schedule 15 filing requirement for the 2023, 2024, and 2025 tax years — so in practice, bare trusts have not had to file since the rule was introduced. The stated purpose of the broader reform: combat money laundering and tax evasion by creating transparency around beneficial ownership.

The practical effect: tens of thousands of trustees who’d never filed a T3 return suddenly had compliance obligations they didn’t know about.

The 2024 and 2025 Filing Seasons: Not a Bare-Trust Story

The March 30, 2025 deadline (extended from March 31 since it fell on a Monday) applied to family trusts, alter ego trusts, and other non-exempt express trusts filing for their 2024 taxation year — a busy first real season for those trusts. Bare trusts were not part of it: CRA’s administrative exemption meant bare trusts did not have to file a T3 return or Schedule 15 for the 2024 tax year, and the same exemption carries through the 2025 tax year (return due March 31, 2026).

Many trustees missed the deadline entirely. Some thought the “one-year grace period” mentioned in early CRA guidance meant they didn’t need to file until 2026. That was a misunderstanding—the grace period applied to penalties for late 2023 filings, not a free pass to skip 2024.

Now we’re in year two of the new regime, and CRA has made it clear: the training wheels are off. Late filings will trigger penalties, and repeated non-compliance will attract audits.

Who Must File: The 2025/2026 Scope

You must file a 2025 T3 return (due March 31, 2026) if you are a trustee of any of the following (bare trusts are excluded — see the bare-trust update above):

Express Trusts (Mandatory Filing)

• Family trusts
• Alter ego trusts
• Joint partner trusts
• Self-benefit trusts
• Estate trusts (with assets exceeding qualified disability trust thresholds)

Exemptions (No Filing Required)

• Bare trusts, for the 2023, 2024, and 2025 tax years (CRA administrative exemption; filing resumes for taxation years ending on or after December 31, 2026, first due March 31, 2027)
• Trusts that existed for less than three months
• Trusts holding less than $50,000 in assets throughout the entire year AND with no tax payable
• Graduated rate estates (GRE) and qualified disability trusts (QDT) below asset thresholds
• Lawyers’ general trust accounts
• Registered plans (RRSPs, TFSAs, RESPs, etc.)

The devil is in the details for the trusts still in scope — but bare trusts remain outside the current filing requirement. A bare trust holding a $600,000 Toronto condo for your adult child, or a joint bank account where you’re named for convenience while your elderly parent retains beneficial ownership, does not need a T3 return or Schedule 15 for the 2023, 2024, or 2025 tax years under CRA’s bare-trust exemption. That changes for taxation years ending on or after December 31, 2026.

Schedule 15: Beneficial Ownership Reporting

This is the big one. Schedule 15 requires detailed disclosure of:

Trustees

• Full legal name
• Date of birth
• Country of residence
• Residential address (no P.O. boxes)
• SIN or business number
• Jurisdiction of residence for tax purposes

Beneficiaries

• Same information as trustees
• Specification of beneficial interest (income, capital, or both)
• Percentage of beneficial interest if determinable
• Whether beneficiary is settlor

Settlors

• Same personal information
• Date trust was settled
• Fair market value of initial settlement
• Description of property settled

Persons with Control or Influence

• Anyone who can control trustee decisions
• Anyone who can effectively control distributions
• This includes protectors, advisors, or de facto controllers even if not formally named in trust deed

Common Mistakes We’re Seeing (And How to Avoid Them)

Mistake 1: Assuming No Income Means No Filing

Wrong. Even if the trust had zero income in 2025, if it meets the definition of an express trust and doesn’t fall under an exemption, you must file. The T3 will show $0 income, but Schedule 15 must still be completed.

Mistake 2: Incomplete Beneficial Ownership Information

You can’t leave fields blank because “the information is private” or “we don’t want to disclose.” If you don’t have complete information for all required parties, you need to obtain it before filing. Incomplete Schedule 15 forms will be rejected, and re-filing after March 31 triggers late penalties.

Mistake 3: Misunderstanding “Control”

Many trustees list only formal trustees and named beneficiaries, ignoring de facto controllers. If mom can call you and tell you to distribute funds, and you always comply, mom has control even if she’s not a formal trustee. She must be disclosed.

Mistake 4: Bare Trust Confusion

If you’re holding property for someone else under a verbal agreement, you’re probably a bare trustee. This includes:

• Adult child on parents’ deed for estate planning purposes
• Parent on adult child’s deed to help qualify for mortgage
• Business partner holding shares in trust pending partnership documentation
• Joint bank accounts where one party is named for convenience only

None of these currently trigger a T3 filing requirement — CRA’s bare-trust exemption covers the 2023, 2024, and 2025 tax years. Document the arrangement anyway: the exemption ends for taxation years ending on or after December 31, 2026, with the first bare-trust T3/Schedule 15 filings due March 31, 2027.

Penalties: What Non-Compliance Costs

CRA is not messing around. Here’s the penalty structure:

Failure to File on Time
$25 per day, minimum $100, maximum $2,500 for individuals. For corporations and trusts with corporate trustees, multiply by 5.

Gross Negligence (Repeated Non-Compliance)
Up to $12,500 for failure to file, plus 5% of maximum FMV of trust property for knowingly failing to provide required information.

Criminal Penalties
In extreme cases, conviction for tax evasion can result in fines up to 200% of tax sought to be evaded, plus imprisonment up to 5 years.

Because bare trusts have been exempt from filing since the rule was introduced, CRA has not assessed bare-trust filers for missing a T3/Schedule 15 deadline in 2023, 2024, or 2025 — no such deadline applied to them. That changes for the 2026 tax year: once the reportable-bare-trust rules take effect, the standard $25/day (minimum $100, maximum $2,500 for individuals) failure-to-file penalty will apply to bare trusts that miss the March 31, 2027 deadline.

How to File: Practical Steps for the Next 12 Days

Step 1: Determine if You’re a Trustee

Review any property you hold jointly, any property titled in your name but beneficially owned by others, and any formal trust arrangements. If uncertain, consult with a CPA or lawyer.

Step 2: Gather Required Information

For every trustee, beneficiary, settlor, and person with control:

• Full legal name (as it appears on government ID)
• Date of birth
• SIN (for Canadian residents) or foreign tax ID
• Current residential address
• Country and jurisdiction of tax residence

Step 3: Prepare the T3 Return

You can file electronically through CRA’s Trust account or using certified tax software. Paper filing is possible but slower and more error-prone.

Complete:

• T3 main form (income, deductions, distributions)
• Schedule 9 (income allocations to beneficiaries)
• Schedule 15 (beneficial ownership)

Step 4: File Before March 31, 2026

Electronic filing through a tax professional is fastest and generates immediate confirmation. If you’re cutting it close, electronic is the only safe option.

Step 5: Retain Documentation

Keep copies of the trust deed, beneficiary lists, financial statements, and all supporting documentation for six years from the filing date.

Strategic Considerations: Is the Trust Still Worth It?

Here’s a conversation more families should be having: given the increased compliance burden and cost, does the trust still serve its purpose?

For many bare trusts set up decades ago for estate planning, the answer may be no — especially once the exemption ends. If the property can be re-titled directly to the beneficial owner without triggering significant tax, dissolving the trust before the 2026 tax year may be cleaner and simpler than taking on new T3 filing obligations starting with the return due March 31, 2027.

For family trusts designed to split income or protect assets, the compliance cost is likely worth it—but you need to run the numbers. If you’re paying $1,500/year in accounting fees to maintain a trust that’s saving $800/year in tax, the math doesn’t work.

What CRA Is Looking For in 2026

Based on communications from CRA and patterns from 2024 audits, here’s what’s on their radar:

Bare Trusts (Once the 2026 Rules Take Effect)
Bare trusts aren’t a 2026-filing-season risk area today — they remain exempt through the 2025 tax year. But high-value real estate held in bare-trust arrangements (for example, a parent on title for a child’s property) is expected to be a compliance focus once the reportable-bare-trust rules apply to taxation years ending on or after December 31, 2026 — start gathering beneficial-ownership documentation now.

Family Trusts with Large Distributions
Trusts distributing $100K+ to beneficiaries are more likely to be selected for review. Ensure your distribution resolutions are properly documented and that T3 income allocations match T4A/T5 slips issued to beneficiaries.

Trusts with Foreign Beneficiaries or Settlors
Any cross-border element increases scrutiny. Double-check that NR4 withholding was properly calculated and remitted if distributions went to non-residents.

Get Help Before the Deadline

If you’re reading this on March 19 and realizing you’re a trustee who hasn’t filed, you have time—but not much.

Immediate Action Steps:

• Contact a CPA who specializes in trust taxation
• Gather the required beneficial ownership information
• Prepare and file electronically before March 31

Trying to DIY a complex family trust T3 return under time pressure is risky (bare trusts are not part of this year’s filing requirement — see the bare-trust update above). The cost of professional help ($500-$1,500 depending on complexity) is far less than the cost of penalties, interest, and potential audits from a botched return.

Our team at Insights CPA handles dozens of trust returns each filing season. We have streamlined processes for both simple bare trusts and complex multi-generational family trusts. If you need help before the March 31 deadline, contact us immediately—we can still get you filed on time.

Looking Ahead: Trust Compliance in 2027 and Beyond

CRA has indicated that beneficial ownership reporting requirements may expand further. There’s ongoing discussion about requiring beneficial ownership updates whenever control or beneficial interests change, not just annually.

For trustees, this means compliance is no longer a once-a-year afterthought. You need systems to track:

• Changes in beneficial ownership
• Trustee appointments and resignations
• Distribution resolutions
• Trust amendments
• Property acquisitions and dispositions

If you don’t have a CPA actively managing your trust compliance, now is the time to establish that relationship. The penalties and audit risks are too high to go it alone.

Bottom Line: Don’t Be the Trustee Who Learns the Hard Way

March 31, 2026 is not a soft deadline. It’s a statutory requirement backed by significant penalties. If you’re a trustee of any Canadian trust, your obligations are clear:

• File a 2025 T3 return
• Complete Schedule 15 with full beneficial ownership information
• Submit before March 31, 2026
• Retain documentation for six years

Ignorance of the rules is not a defense CRA accepts. Get informed, get compliant, or get professional help.

For assistance with trust returns, beneficial ownership reporting, or strategic trust planning, reach out to our team. We’re here to help navigate the complexity so you can focus on what matters: serving the best interests of your beneficiaries.

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About the Author
Bader A. Chowdry, CPA, CA, LPA advises Canadian families and business owners on tax-efficient wealth structures, trust compliance, and strategic tax planning. His practice focuses on helping clients navigate complex CRA requirements while minimizing tax exposure. Learn more about trust and estate planning services.

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