Bill C-15: What you need to know about trust reporting requirements

The Canada Revenue Agency (CRA) has published a new tax tip, Important updates to the trust reporting requirements for the 2025 taxation year: What you need to know, to help affected taxpayers understand potential changes to their filing obligations for taxation years ending in 2025. 

On November 18, 2025, the Government of Canada tabled Bill C-15, An Act to implement certain provisions of the budget tabled in Parliament on November 4, 2025, with proposed amendments to the Income Tax Act (ITA) that relate to trust reporting.

Based on the proposed legislation, and consistent with the Explanatory Notes Relating to the Income Tax Act and Other Legislation published by the Department of Finance, the changes could affect filing obligations for certain trusts.

Here is what you need to know:

Bare trusts

The CRA does not expect bare trusts to file a T3 Trust Income Tax and Information Return (T3 return) including Beneficial Ownership Information of a Trust (Schedule 15) for taxation years ending in 2025.

However, certain bare trusts may be required to file for taxation years ending on or after December 31, 2026. This advance notice is intended to help tax professionals and trustees plan ahead for future filing obligations.

“Listed trusts”

Additional trusts are now included as listed trusts. These are trusts which, due to certain conditions, will be exempt from the requirement to:

• file a T3 return annually or

• complete Schedule 15 when filing a T3 return, where the listed trust is still required to file because specific conditions are not met

How changes will be applied

While taxpayers can still choose to file under currently enacted legislation, the CRA confirms that it will administer the proposed changes to the trust reporting rules contained in Bill C-15. The CRA has also updated the 2025 T4013 Trust Guide and T3 return and schedules to reflect these changes. If the proposed legislative changes are not enacted, further direction will be provided at that time.

Check the CRA’s Filing a trust’s T3 return and Enhanced reporting rules for trusts and bare trusts: Frequently asked questions pages for more information on the changes affecting trust reporting.