After three years of last-minute exemptions, bare trust reporting is back, and this time it is law. Bill C-15, the Budget 2025 Implementation Act, No. 1, received Royal Assent on March 26, 2026 (S.C. 2026, c. 3). It narrows the regime the CRA kept deferring, and the CRA now says that certain bare trusts must file for taxation years ending on or after December 31, 2026.
For most arrangements that means a first T3 return, with Schedule 15 beneficial ownership information, due March 31, 2027. The arrangements need to be identified now, while there is still time to gather the information Schedule 15 asks for.
What changed and who it affects
- The change: Bare trusts that were exempt for 2023, 2024 and 2025 become subject to the trust reporting rules again, but only if they are "reportable bare trusts" under subsection 150(1.3) of the Income Tax Act and no exception in subsection 150(1.31) applies.
- When it applies: Taxation years ending on or after December 31, 2026. A bare trust generally has a calendar year, so the first year caught is 2026.
- Who it affects: Anyone who holds legal title to property for someone else, or whose property is held in someone else's name: nominee corporations holding real estate, parents or children on title, "in trust for" accounts, and similar arrangements. The filing obligation sits with the trustee, meaning the legal owner.
Sources: Department of Finance: Legislation passes to implement Budget 2025, Justice Laws: Budget 2025 Implementation Act, No. 1 (S.C. 2026, c. 3) and LEGISinfo: Bill C-15 (45-1).
Bare trust reporting 2026: the timeline
| Taxation year | Bare trust filing requirement | Status |
|---|---|---|
| 2023 | Not expected to file a T3 or Schedule 15 unless the CRA directly requests it | CRA administrative exemption |
| 2024 | Not required to file | Exempt |
| 2025 | Not required to file | Exempt |
| 2026 (years ending on or after Dec 31, 2026) | Reportable bare trusts must file a T3 with Schedule 15, unless an exception or listed-trust status applies | In force (Bill C-15, Royal Assent March 26, 2026) |
| 2027 onward | Same rules each year. Schedule 15 is filed every year, even with no changes | In force |
The T3 is due no later than 90 days after the trust's year-end. For a December 31, 2026 year-end, day 90 is Wednesday, March 31, 2027.
Sources: CRA: Enhanced reporting rules for trusts and bare trusts, FAQ and CRA: What has changed, filing a trust's T3 return.
Which bare trusts are not reportable: the exceptions
The new regime is much narrower than the version the CRA deferred in 2024. Subsection 150(1.31) carves out several common arrangements. The CRA's FAQ describes them, including:
| Arrangement | Reportable for 2026? | Why |
|---|---|---|
| Every beneficial owner is also a legal owner, and every legal owner is a beneficial owner (for example, a joint family bank account owned by the people on it) | No | Excepted under 150(1.31) |
| Related individuals on title to real property that would be a principal residence of a beneficiary (for example, a parent on title so a child can get a mortgage) | No | Excepted under 150(1.31) |
| Property held solely for the use of a partnership, where each legal owner is a partner | No | Excepted under 150(1.31) |
| A nominee or bare trustee corporation holding real estate for an operating company, a holding company or individuals | Generally yes, unless another exception or listed-trust status applies | The legal owner is not a beneficial owner |
| An "in trust for" account or other arrangement where someone holds title for another person and the property is above the thresholds below | Generally yes | No exception applies |
The exceptions are fact-specific. The parent-on-title exception, for instance, depends on the people being related and on the property being a principal residence of a beneficiary. Read the CRA's worked examples before concluding an arrangement is out.
The listed-trust thresholds: $50,000 and $250,000
Even a reportable bare trust does not need to file a T3 or Schedule 15 if it is a listed trust for the year, unless the CRA asks it to file. Two asset thresholds matter:
| Threshold | Applies when | Condition |
|---|---|---|
| $50,000 | Any type of asset | Total fair market value of the trust property did not exceed $50,000 at any time in the year |
| $250,000 | Only the specific asset types listed in the Act | Each trustee is an individual, and each beneficiary is an individual (other than a trust) related to each trustee; fair market value did not exceed $250,000 at any time in the year |
The test is throughout the year, not at year-end. A property worth more than the threshold for even part of 2026 fails it. Real estate held by a nominee will almost always be above both.
Source: CRA: Enhanced reporting rules for trusts and bare trusts, FAQ.
What a reportable bare trust actually files
The return is lighter than a regular trust's:
- The T3 return, completing only the lines the CRA marks as applying to reportable bare trusts. The remaining parts can be left blank.
- Schedule 15, the beneficial ownership schedule: identifying information for the trustees, beneficiaries, settlors and anyone with control over the trust.
- No income on the trust return. All income, capital gains and capital losses from the property stay on the beneficial owner's own return, as they always have.
Schedule 15 is required every year, even if nothing changed, although unchanged information reported earlier can be carried forward. If a required T3 or the Schedule 15 information is not filed by the due date, the CRA can charge a late-filing penalty.
Sources: CRA: T3 Trust Guide (T4013) and CRA: Who should file a T3 return.
Edge cases business owners get wrong
The corporation on title is the trustee, not you. Where a nominee corporation holds a building for your operating company, the nominee is the legal owner and the one with the filing obligation. Its own T2 does not cover this. The T3 is a separate return with its own trust account number.
A transfer partway through the year still counts. Because the listed-trust thresholds apply at any time in the year, an arrangement that held a valuable property for only a few months of 2026 can still be reportable for 2026.
Associated companies and joint ventures. Property held by one company for several unrelated co-owners does not fit the "every legal owner is a beneficial owner" exception, and the related-individual exception does not apply to corporations. Expect these to be reportable.
Non-calendar year-ends. The rules apply to years ending on or after December 31, 2026. Bare trusts generally use a calendar year, but if an arrangement has a different year-end, the first year caught and its 90-day deadline follow that year-end.
2025 is still clear, unless the CRA asks. You do not need to go back and file for 2023, 2024 or 2025, but a direct request from the CRA for an earlier year must be answered.
What to do before December 31, 2026
- List every arrangement where someone holds title to property for someone else: nominee companies, family members on title, trust accounts held for children, real estate held for a partnership or joint venture.
- Test each one against the exceptions and the $50,000 and $250,000 listed-trust thresholds, using the highest value during 2026.
- Collect the Schedule 15 information for those that remain: names, addresses, dates of birth, jurisdictions of residence and taxpayer identification numbers for every trustee, beneficiary and settlor.
- Diarize March 31, 2027 as the trustee's deadline, and apply for a trust account number early if the arrangement does not have one.
Key takeaways
- Bare trust reporting for 2026 is law: Bill C-15 received Royal Assent on March 26, 2026, and applies to taxation years ending on or after December 31, 2026.
- The first T3 and Schedule 15 are due March 31, 2027 for calendar-year bare trusts.
- Joint owners, parents on a child's principal residence and partnership property are excepted; nominee corporations holding real estate generally are not.
- The $50,000 and $250,000 thresholds are tested throughout the year, not at year-end.
RN Canada prepares T3 returns, including Schedule 15, alongside the corporate and personal returns of owner-managed businesses, and can review your nominee and family arrangements against the 2026 exceptions before year-end. Talk to our corporate and personal tax team, or see our tax return preparation service.