--- title: "Trust Reporting Rules in Canada: The T3 | EverStone" url: https://www.everstonecpa.com/blog/trust-reporting-rules-canada-t3 description: "Canada’s expanded trust reporting rules pull most trusts into an annual T3 return and Schedule 15 disclosure. See who is caught and what must be reported." type: guide updated: 2026-10-04 summary: "Canada’s expanded trust reporting rules require most express trusts to file a T3 return annually and disclose everyone connected to the trust on Schedule 15 — trustees, settlors, beneficiaries and controlling persons. The rules took effect for tax years ending on or after December 31, 2023 and have been amended since." faq_count: 6 publisher: EverStone CPA Inc., a Chartered Professional Accountant firm registered with CPA British Columbia and CPA Alberta service_area: British Columbia, Alberta, Ontario and Manitoba language: en-CA contact: info@everstonecpa.com · https://www.everstonecpa.com/book-online --- [Home](https://www.everstonecpa.com/) [Blog](https://www.everstonecpa.com/blog) Expanded trust reporting in Canada: who the T3 return now catches Tax # Expanded trust reporting: *who the T3 now catches* By EverStone CPA · Updated September 2026 · 9 min read **Quick answer:** Canada’s expanded trust reporting rules require most express trusts to file a T3 return annually and disclose everyone connected to the trust on Schedule 15 — trustees, settlors, beneficiaries and controlling persons. The rules took effect for tax years ending on or after December 31, 2023 and have been amended since. The default reversed: file unless the trust is excused. **Rather have a CPA handle this?** A CPA at EverStone replies with a straight answer and a fixed fee for your situation. [Get My Fixed Quote →](https://www.everstonecpa.com/book-online) ## Key takeaways - The enhanced rules apply to T3 returns for taxation years ending on or after December 31, 2023, and have been amended for later years. - A resident express trust must generally file annually unless it is a listed trust, and those categories have been expanded more than once. - Trusts that must file, other than listed trusts, also file Schedule 15 disclosing specified information about every reportable entity. - Reportable entities are trustees, settlors, beneficiaries and controlling persons; confirm the position for the specific taxation year, since the rules keep changing. For most of their history, a great many Canadian trusts filed nothing. If a trust had no tax payable and no dispositions, there was frequently no return to file. That changed. Canada’s enhanced trust reporting rules reversed the default: the question is no longer whether a trust has something to report, but whether it is excused from reporting. ## What the enhanced T3 trust reporting rules did The rules governing which trusts must file an annual T3 Trust Income Tax and Information Return were enhanced for taxation years ending on or after December 31, 2023. The CRA sets out three main additions for that first year: - All trusts, unless certain conditions are met, are required to file a T3 return annually. - Generally, all trusts required to file, other than listed trusts, must include specified information about each reportable entity on Schedule 15, filed with the T3 return. - Bare trusts were brought inside the reporting rules, a point with its own complicated history, covered in the [guide to bare trust reporting](https://www.everstonecpa.com/blog/bare-trust-reporting-canada). The CRA says the purpose is verification: confirming that trusts, trustees, beneficiaries and related parties meet their *Income Tax Act* obligations. For a small business family, once-invisible arrangements now produce an annual filing with names attached. **Want a CPA to handle this for you?** Tell us about your business and get a fixed fee in writing within one business day. See [our published fees](https://www.everstonecpa.com/pricing), or [get a fixed quote](https://www.everstonecpa.com/book-online). [Get My Fixed Quote](https://www.everstonecpa.com/book-online) ## Which trusts are now required to file A trust resident in Canada, other than a listed trust, must file a T3 return annually if the trust is an express trust, or, for civil law purposes, a trust other than one established by law or by judgment. That is a deliberately wide net. For all other trusts, resident and non-resident, a return is required for any year in which a familiar trigger applies: tax payable, a request to file, deemed residence, a disposition or deemed disposition of capital property, a taxable capital gain, or holding property subject to subsection 75(2). The category doing the real work is the **listed trust**, which is exempt from both the annual filing requirement and the Schedule 15 disclosure. That list is where nearly all the later amendments landed: additional trusts were added for taxation years ending on or after December 31, 2024, and further additions for years ending on or after December 31, 2025. **The rules have been amended in each of the last several years.** The CRA’s own guidance is organized year by year for exactly this reason, with separate answers for taxation years ending on or after December 31, 2023, 2024, 2025 and 2026. Confirm the position for the year you are filing rather than the year you last looked. Not sure how this applies to you? Every corporation is different. Send an enquiry for a straight answer and a fixed quote. [Send an Enquiry →](https://www.everstonecpa.com/book-online) [See fixed fees](https://www.everstonecpa.com/pricing) ## What Schedule 15 actually discloses Schedule 15, *Beneficial Ownership Information of a Trust*, is the substantive part of the regime. It requests specified information on all trustees, settlors, beneficiaries and controlling persons — the reportable entities. For each, the trust reports: - Name and address - Date of birth, if an individual - Country of residence - Tax identification number, a social insurance number, business number, trust number, or the identification number used in a foreign jurisdiction for a non-resident trust Schedule 15 is filed each year with the return when required, even if nothing has changed, although previously reported information can be carried forward. Where a beneficiary’s identity is not known or ascertainable with reasonable effort — unborn grandchildren, for instance — the return instead describes the class in enough detail to determine with certainty whether any particular person is a beneficiary. Two practical points follow. The trustee must collect tax identification numbers from people who may have no interest in providing them, and the CRA notes that a reportable entity failing to do so may face a penalty under subsection 162(6). The trustee should also document the effort made, because that record is the answer if completeness is questioned. ## Who is a settlor, and why that answer moved The definition of settlor shows how live this area is. For taxation years ending before December 31, 2024, it took its meaning from subsection 17(15). For years ending on or after that date, the rules use a broader meaning: any person or partnership that transferred property to the trust, directly or indirectly, other than for fair market value consideration or pursuant to a legal obligation. That can capture a family member who contributed property years ago. ## What happens if the filing is missed or incomplete Trust filing penalties Penalties for a missed or misstated trust filing, as described on this page. | Failure | Penalty | Range | | Failure to file, no unpaid taxes at the deadline | $25 a day under subsection 162(7) | $100 minimum, $2,500 maximum | | False statement or omission, knowingly or through gross negligence | The greater of $2,500 and 5% of the highest fair market value of trust property in the year | A further penalty, on top | Failing to file, or filing without complete specified information, may result in a late-filing penalty. Where a trust that failed to file has no unpaid taxes at the deadline, the CRA describes a subsection 162(7) penalty of $25 a day, from $100 to a maximum of $2,500. Where the trust is not a listed trust and a false statement or omission is made knowingly or through gross negligence, a further penalty applies of the greater of $2,500 and 5% of the highest fair market value of trust property in the year. It is measured against property rather than tax owing, so it can be large for a trust that owes nothing. ## What this means for a small business family Family trusts holding shares of an operating company are the common case. If a trust sits above your corporation, often set up alongside an [estate freeze](https://www.everstonecpa.com/blog/estate-freeze-canada-small-business), the checklist is short: - Confirm whether the trust is a listed trust *for the taxation year in question*, not in general. - Build the reportable entity list from the trust deed and the actual history of transfers into the trust, not from memory. - Collect tax identification numbers early. This is the step that delays filings. - Keep the deed findable, much like a [corporate minute book](https://www.everstonecpa.com/blog/keeping-a-minute-book-canada-corporation). ## The bottom line Expanded trust reporting is about visibility more than tax. A filing may report no dollars yet disclose exactly who stands behind an arrangement, which is the point. The boundary has moved in each of the last several years, so redo the annual determination rather than reuse it. Sources - [Canada Revenue Agency — Enhanced reporting rules for trusts and bare trusts: FAQ](https://www.canada.ca/en/revenue-agency/services/tax/trust-administrators/t3-return/enhanced-reporting-rules-trusts-bare-trusts-faq.html) - [Canada Revenue Agency — Trust income tax return](https://www.canada.ca/en/revenue-agency/services/tax/trust-administrators/t3-return.html) - [Canada Revenue Agency — T4013, T3 Trust Guide](https://www.canada.ca/en/revenue-agency/services/forms-publications/publications/t4013.html) This article is general information for Canadian business owners and is current as of July 2026. It is not tax, legal or accounting advice, and it does not create a client relationship. Tax rules change and your situation is unique, so please [speak with a CPA](https://www.everstonecpa.com/book-online) before acting on anything here. About this article **EverStone CPA** Prepared and reviewed by a CPA at EverStone CPA, serving businesses in BC, Alberta, Ontario and Manitoba. [About the firm →](https://www.everstonecpa.com/about) · [Send an enquiry →](https://www.everstonecpa.com/book-online) ### Keep reading [Bare trust reporting in Canada →](https://www.everstonecpa.com/blog/bare-trust-reporting-canada) [Estate freezes explained →](https://www.everstonecpa.com/blog/estate-freeze-canada-small-business) [Corporate tax services →](https://www.everstonecpa.com/tax-services) [Bare trust reporting: 2025 and 2026 →](https://www.everstonecpa.com/tax-update/bare-trust-reporting) FAQ ## Frequently asked questions **Which trusts have to file a T3 return under the enhanced rules?** A trust resident in Canada, other than a listed trust, must generally file annually if it is an express trust. All other trusts must file for any year in which a trigger applies — tax payable, a request to file, deemed residence, a disposition, or a taxable capital gain. **What is a listed trust?** A listed trust is a category exempted from the annual filing requirement and from the Schedule 15 disclosure. The categories have been expanded more than once, with additions for taxation years ending on or after December 31, 2024 and again for years ending on or after December 31, 2025. **What information does Schedule 15 require?** Schedule 15 requests specified information on all trustees, settlors, beneficiaries and controlling persons — the reportable entities. For each, the trust reports name, address, date of birth if an individual, country of residence, and a tax identification number. **What if a beneficiary cannot be identified?** Where a beneficiary’s identity is not known or ascertainable with reasonable effort — unborn grandchildren, for example — the person making the return provides information detailed enough to determine with certainty whether any particular person is a beneficiary. **Who counts as a settlor for trust reporting?** That depends on the year. For taxation years ending before December 31, 2024, settlor took its meaning from subsection 17(15). For years ending on or after that date, the rules treat a settlor as any person or partnership that transferred property to the trust, excluding transfers for fair market value consideration or made pursuant to a legal obligation. **What are the penalties for not filing or filing incomplete information?** Where a trust that failed to file has no unpaid taxes at the deadline, the CRA describes a subsection 162(7) penalty of $25 a day, from $100 to a maximum of $2,500. Where a false statement or omission is made knowingly or through gross negligence, a further penalty applies of the greater of $2,500 and 5% of the highest fair market value of trust property in the year. ## Have a family trust and no idea whether it has to file? The answer depends on the taxation year and on whether the trust is a listed trust for that year. Send an enquiry to have the position reviewed. 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