T3 Schedule 15: Does your trust have additional reporting requirements?

Updated: September 15, 2025

If you have a trust, you may now be required to annually report additional information on the trust’s stakeholders—including beneficiaries, settlors, trustees, and certain other parties. Specifically, you may need to file T3 Schedule 15 “Beneficial ownership information of a trust” as part of your trust’s T3 return, for tax years ending on or after December 31, 2023. Note that Schedule 15 requires detailed information which can take time to gather and update each year.  

In its last update, the federal government proposed changes to add or broaden exceptions to filing requirements. These amendments were released in draft legislation on August 15, 2025. 

It’s critical that you determine your trust’s reporting requirements each tax year as the non-compliance penalties are significant. 

What are the current reporting requirements on beneficial ownership?

Who must file Schedule 15?

Many trusts are required to file Schedule 15 annually as part of the T3 return, subject to certain exceptions. Specifically, the trust reporting rules require express trusts resident in Canada, as well as non-resident trusts deemed resident in Canada to report information on their beneficial ownership.  
Generally, an express trust is a trust created with the settlor’s express intent, either formally or informally. As this definition is very broad, most types of trusts are express trusts.  

Certain trusts that were previously not required to file T3 returns, including bare trusts, are now required to file T3 returns including Schedule 15, beginning with December 31, 2023 tax years. 

However, the CRA administratively exempted bare trusts from filing 2023 and 2024 T3 returns, unless requested.   

What are the exceptions?

Under the current rules, the following types of trusts aren’t required to file Schedule 15; however, a T3 return is generally still required: 

• Graduated rate estates  
• Trusts that have been in existence for less than three months at the end of the year 
• Trusts that hold a total fair market value (FMV) of $50,000 or less in assets throughout the tax year (provided their holdings are limited to money, government debt obligation, and listed securities) 
• Mutual fund trusts, segregated funds, and master trusts 
• Trusts governed by certain registered plans (e.g., registered retirement savings plans)  
• Lawyers’ and other professionals’ general trust accounts where the funds are required to be held in trust under the relevant rules of professional conduct or federal or provincial law  
• Qualified disability trusts, employee life and health trusts, and certain government-funded trusts  
• Trusts that are registered charities (including internal trusts held by charities under CRA administrative relief) 
• Trusts that qualify as non-profit organizations (NPOs). However, internal trusts held by NPOs must still file Schedule 15 unless they meet another exception on this list. 
• Trusts whose units are all listed on a designated stock exchange  
• Cemetery care trusts and trusts governed by eligible funeral arrangements  
• Trusts under an employee profit sharing plan  

What information is reported on Schedule 15?

If your trust has to file Schedule 15, you must provide additional information on the trust’s stakeholders, including their name, address, date of birth (where applicable), jurisdiction of tax residence, and tax information number. Such stakeholders include trustees, beneficiaries, and settlors of the trust, and anyone who has the ability (through the trust terms or a related agreement) to exert control or override trustee decisions over the appointment of income or capital of the trust (i.e., a protector).

Under the current rules for Schedule 15, a settlor includes an individual or entity that loaned or transferred property directly or indirectly to (or for the benefit of) the trust. There’s an exclusion available for arm’s length lenders where a reasonable rate of interest is charged. Similarly, there’s an exclusion for arm’s length transferors, provided the transfer was at FMV.

The meaning of “beneficiary” includes contingent beneficiaries, as well as unknown beneficiaries in certain cases (e.g., future children or grandchildren).  

What are the non-compliance penalties?

T3 returns (including Schedule 15 where required) are due within 90 days of a trust’s tax year end. 

Failure to comply with these requirements will result in significant penalties. If a trust fails to meet the filing deadline, it will be subject to a penalty of $25 per day, with a minimum penalty of $100 and a maximum of $2,500. If a trust fails to file—either knowingly or due to gross negligence—an additional penalty, equal to the greater of $2,500 and 5% of the maximum value of property held during the year, may apply.  

Proposals for expanded exemptions 

The August 15 draft legislation proposes to broaden the list of exemptions from having to file Schedule 15. If enacted, the following types of trust won’t be required to file for tax years ending December 31, 2024 and onwards: 

• Trusts whose assets have a total FMV of $50,000 or less throughout the tax year without restrictions on asset type (instead of the current $50,000 exemption with restrictions on asset type). 
• Trusts that have existed for less than three months during the year (instead of at the end of the year)  
• Trusts that would be graduated rate estates if the estate had filed a return for the year 
• Trusts that meet all the following conditions: 
  • All trustees and beneficiaries are individuals. The condition broadens for tax years ending December 31, 2025 and onwards so that a beneficiary can also be a graduated rate estate of an individual.  
  • Each beneficiary is related to each trustee. The definition of “related” broadens for tax years ending December 31, 2025 and onwards to include an aunt/uncle, niece/nephew, and oneself. 
  • The total FMV of the trust property is $250,000 or less throughout the tax year, provided the trust’s holdings are limited to certain types of assets (e.g., money, listed securities, guaranteed investment certificates issued by Canadian banks, personal-use property, and debt obligations issued by the government or a publicly listed entity). This list of assets broadens further for tax years ending December 31, 2025 onwards to include deposits in a Canadian bank, trust company, or credit union, and a GIC issued by a credit union.  
• Lawyers’ and other professionals’ client-specific trust accounts that meet both of the following conditions: 
  
  • The funds are required to be held in trust under the relevant rules of professional conduct or federal or provincial law 
  • The only assets held within the trust throughout the year is money with a value of $250,000 or less. For taxation years ending December 31, 2025 and onwards, the assets could also include deposits in a Canadian bank or credit union, and GICs issued by a Canadian bank, trust company, or credit union.  
• Certain statutorily-created trusts requiring the trustee to hold the property for a specified purpose, such as those of bankruptcy trustees.  

Employee ownership trusts and certain trusts governed by a retirement compensation arrangement are also proposed to be exempt for tax years ending December 31, 2025 and onwards  

There are additional proposed exemptions for certain bare trusts. Please refer to our Bare trusts: What are they and who has to report? tax alert. 

Other notable proposals  

Finance proposes to narrow the definition of a settlor for Schedule 15 to exclude lenders. Specifically, a settlor would include any person or partnership that has directly or indirectly transferred property to the trust. This excludes transfers at FMV or pursuant to a legal obligation, regardless of whether the transferor is non-arm’s length or arm’s length.  

If enacted, this change would apply for taxation years ending December 31, 2024 and onwards.  

Finance also proposes to exempt alter ego and joint spousal or common-law trusts from disclosing contingent beneficiaries. If enacted, this would apply to taxation years ending December 31, 2025 and onwards.   

For help navigating the trust reporting rules and how the proposed changes may impact your trust, contact your local advisor or reach out to us here.

^Disclaimer 

^{The information contained herein is general in nature and is based on proposals that are subject to change. It is not, and should not be construed as, accounting, legal or tax advice or an opinion provided by Doane Grant Thornton LLP to the reader. This material may not be applicable to, or suitable for, specific circumstances or needs and may require consideration of other factors not described herein.}