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Changes to trust reporting for Dec. 31, 2025 trust year-ends

Updated: February 23, 2026

On Nov. 18, 2025, the government tabled Bill C-15 which contains legislative proposals on several topics, including amendments to trust reporting. These changes would partially relieve the existing rules that apply to trust reporting and first applied to the 2023 taxation year. 

This article discusses proposed changes to trusts (other than bare trusts) and would apply to trusts with a fiscal year ending on or after Dec. 31, 2025. Proposals that apply to bare trust reporting are discussed in a separate article, Bare trusts: Proposed changes for 2025 filings.

The general rule is that all trusts (with some exceptions) must report information annually on their T3 return. Since 2023, Schedule 15 is required for most trusts. It requires enhanced information—including the name, address, date of birth, country of residence, and taxpayer identification number—for each settlor, trustee, beneficiary, and each person who has the ability to exert control or override trustee decisions over the appointment of income or capital of the trust (e.g., a protector).

For subsequent years, only changes to items reported in the previous Schedule 15 need to be reported. For example, if a beneficiary moved or if a trustee was replaced, these changes need to be reported. However, if there has been no change in the information reported, no new information need to be provided and the corresponding box on Schedule 15 should be marked accordingly.

Under current law, the two most common exceptions to the enhanced reporting requirements in Schedule 15 for express trusts are:

  • trusts that have been in existence for less than three months prior to the year-end; and 
  • trusts that hold assets with a total fair market value not exceeding $50,000 throughout the year and where these assets consist solely of money and certain exempted marketable securities throughout the year.

Exemptions for small trusts

Proposed changes for 2025 contained in Bill C-15 would expand the exemptions for small or short-term trusts.

First, it is proposed to amend the exemption for trusts that have been in existence for less than three months at the end of the year to apply to trusts that have been in existence for less than three months. This could exempt a trust in existence for less than three months where the period ends at any time in the year, including trusts that started near the end of the previous year.

As a further change, all trusts holding assets with a total fair market value of less than $50,000 throughout the year would be considered listed trusts and exempt from Schedule 15 reporting requirements for the 2025 tax year regardless of the type of assets held in these trusts.

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Exemptions for trusts with assets under $250,000 that meet certain conditions 

The proposed amendments also introduce a new exception, which would apply when all of the following conditions are met:

  • Each trustee is an individual;
  • Each beneficiary is:
    • (i) an individual (other than a trust) and is related to each trustee or
    • (ii) a graduated rate estate of an individual who was a beneficiary referred to in paragraph (i) during the year of the individual's death; and
  • The total fair market value of the property of the trust does not exceed $250,000 throughout the year and the only assets held throughout the year consist of one or more of the items listed below.

The following list includes assets exempted under current law and proposed amendments:

  • Money, including deposits in a Canadian financial institution;
  • A guaranteed deposit certificate issued by a Canadian bank, trust company or credit union incorporated under federal or provincial laws;
  • Certain government debt obligations;
    • Debt obligations issued by:
      • (i) a corporation, mutual fund trust, or limited partnership whose securities are listed on a designated exchange in Canada,
      • (ii) a company whose shares are listed on a designated stock exchange outside Canada,
      • (iii) an authorized foreign bank that are payable at a branch in Canada of the bank;
  • A share, debt obligation or right listed on a designated stock exchange;
  • A share of the capital stock of a mutual fund corporation;
  • A unit of a mutual fund trust;
  • An interest in a related segregated fund trust;
  • An interest as a beneficiary under a trust, all of the units of which are listed on a designated stock exchange;
  • Personal-use property of the trust; and
  • A right to receive income or gains on property described above.

Other trust exemptions

An exemption from reporting requirements would be available for trusts that are required (under the applicable rules of professional conduct or the laws of Canada or a province) to hold funds for an activity subject to those rules or laws provided the trust is not maintained as a separate trust for a particular client. This exemption would be modified to also apply to specific accounts provided that the only asset held by the trust throughout the year is cash with a value not exceeding $250,000.

In addition, a new exception has been proposed for trusts created to comply with a law of Canada or a province that requires one or more persons acting as trustees of the trust to hold property in trust for a specific purpose such as in the case of bankruptcy trusteeships or provincial guardianships.

Definition of settlor

Finally, the definition of settlor will now be more restrictive in order to better reflect what is generally understood. For the purposes of the enhanced reporting requirements, the settlor specifically means any person or partnership who has made a transfer of property (directly or indirectly and in any manner) to the trust at or prior to that time. However, transfers made by the person or partnership to the trust for consideration equal to the fair market value or pursuant to a legal obligation are excluded from this definition.

Penalties

Penalties for failing to file the T3 trust return and Schedule 15 for beneficial ownership reporting purposes can be significant. Therefore, it’s important to verify whether the exceptions apply to your situation and to file a trust return (and Schedule 15 where required) by the due date of March 31, 2026.

Legislative proposals

The proposed changes presented in this article have not yet come into force. It’s possible these changes will come into effect by March 31, 2026, which is the deadline for filing a 2025 return for affected trusts. However, the CRA has announced that it will administer the proposed changes to the trust reporting rules contained in Bill C-15, allowing taxpayers to take advantage of the enhanced proposed exemptions in their 2025 trust filings. The CRA also stated that if these changes are not enacted into law, it would provide further direction at that time.

How BDO can help

If you have questions regarding required trust reporting for 2025, please contact your local BDO advisor today.

Rachel Gervais
Managing Partner, Tax
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Greg London
Partner, Domestic Tax Consulting Leader
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The information in this publication is current as of Feb. 3, 2026.

This publication has been carefully prepared, but it has been written in general terms and should be seen as broad guidance only. The publication cannot be relied upon to cover specific situations and you should not act, or refrain from acting, upon the information contained therein without obtaining specific professional advice. Please contact BDO Canada LLP to discuss these matters in the context of your particular circumstances. BDO Canada LLP, its partners, employees and agents do not accept or assume any liability or duty of care for any loss arising from any action taken or not taken by anyone in reliance on the information in this publication or for any decision based on it.