Do bare trusts have to file a T3 and Schedule 15 for 2025 and 2026?
As of October 2026, bare trusts do not file a T3 return or Schedule 15 for taxation years ending in 2024 or 2025. Bill C-15 received Royal Assent on March 26, 2026, and reportable bare trusts must file for years ending on or after December 31, 2026, so the first returns are due March 31, 2027.
Bare trust filing status by tax year, as of October 2026
Bare trusts have filed nothing for three years running, and that stops with the 2026 year. The new rules aren't a proposal anymore: Bill C-15 was enacted as the Budget 2025 Implementation Act, No. 1 (S.C. 2026, c. 3), assented to on March 26, 2026 laws-lois.justice.gc.ca.
| Taxation year ending | Does a bare trust file a T3 and Schedule 15? | Why |
|---|---|---|
| 2023 | No, unless the CRA asks directly | CRA administrative waiver, March 28, 2024 |
| 2024 | No, unless the CRA asks directly | CRA waiver, October 29, 2024; the old 150(1.3) was later repealed for years ending after December 30, 2024 |
| 2025 | No | CRA tax tip, March 5, 2026, then Bill C-15 |
| 2026 and later | Yes, if it is a reportable bare trust, no 150(1.31) exception applies and it is not a listed trust | New 150(1.3), for years ending after December 30, 2026 |
The CRA's FAQ, updated October 5, 2026, says bare trusts are not subject to the trust reporting rules for taxation years ending on or after December 31, 2024 and before December 31, 2026, and that reportable bare trusts are subject to them from December 31, 2026 canada.ca. Its "What has changed" page puts the start date at the same point
canada.ca.
A T3 is due no later than 90 days after the trust's year end canada.ca. For a December 31, 2026 year end, that's 31 days of January, 28 of February and 31 of March: March 31, 2027. The T3 filing deadline page covers weekends and other year ends.
How bare trust reporting got here: the dated history
| Date | What happened |
|---|---|
| March 28, 2024 | CRA exempts bare trusts from filing for the 2023 tax year, unless it asks directly |
| October 29, 2024 | CRA extends the same exemption to the 2024 tax year |
| November 4, 2025 | Budget 2025 tabled; Bill C-15 implements it |
| March 5, 2026 | CRA says it won't expect bare trusts to file for years ending in 2025 and will administer Bill C-15 |
| March 26, 2026 | Bill C-15 receives Royal Assent (S.C. 2026, c. 3) |
| October 5, 2026 | CRA FAQ updated for the enacted rules |
| December 31, 2026 | First year end caught by the new 150(1.3) |
| March 31, 2027 | First T3 and Schedule 15 due for a reportable bare trust |
The 2023 relief came by tax tip on March 28, 2024 canada.ca. The 2024 relief was announced the same way and called a continuation of that exemption
canada.ca. For 2025, the CRA said it would administer the Bill C-15 changes before they passed, and that it would give further direction if they weren't enacted
canada.ca. They were.
Section 71 of the Act does the work. It repeals the old 150(1.3) for taxation years ending after December 30, 2024, and adds the new 150(1.3), 150(1.31) and 150(1.32) for taxation years ending after December 30, 2026. That statutory gap is why 2024 and 2025 are now exempt by law, not just by CRA practice.
What counts as a bare trust: the agency test in 150(1.3)
For the filing rules, a trust includes an express trust where one or more legal owners hold property for the use or benefit of others and the legal owner "can reasonably be considered to act as agent" for them. Each legal owner is treated as a trustee, and each person or partnership with the use or benefit of the property is a beneficiary laws-lois.justice.gc.ca.
So the question is who controls the property. If the person on title takes instructions from someone else and has no independent powers, you're looking at a bare trust. Whether an express trust exists at all is a question of fact and of the province's private law, and the CRA won't decide it for your client canada.ca.
Nothing changes for income tax. The beneficial owner still reports the income from the property on their own return canada.ca. The T3 here is an information filing.
Common bare trust arrangements under the 2026 rules
Two filters decide whether a reportable bare trust actually files. First, the exceptions in 150(1.31) take some arrangements out of 150(1.3) altogether. Second, a reportable bare trust that is a listed trust under 150(1.2) files only if the CRA asks.
| Arrangement | Typical 2026 result | Provision |
|---|---|---|
| Spouses on a joint account, each owning and benefiting | Not reportable | 150(1.31)(a) |
| Parent on title so a child can get a mortgage on the child's home | Not reportable | 150(1.31)(b) |
| One spouse on title of the home both spouses live in | Not reportable | 150(1.31)(c) |
| Adult child added to title of a parent's home for probate | Not reportable while the parent, also on title, lives there | 150(1.31)(b) |
| Adult child added to a parent's investment account for probate, as agent | Reportable; no filing if a listed trust | 150(1.2)(b), (b.1) |
| Parent holding an investment account for a child, as agent | Reportable; no filing if a listed trust | 150(1.2)(b), (b.1) |
| Nominee corporation holding real estate for its owner | Reportable and usually files | Real estate isn't on the (b.1) asset list |
The listed trust tests that matter for bare trusts are in 150(1.2): total fair market value of $50,000 or less throughout the year with any assets, or $250,000 or less throughout the year where every trustee is an individual, every beneficiary is an individual related to each trustee, and the trust holds only listed assets such as money, GICs, listed shares and debt, mutual fund units and personal use property laws-lois.justice.gc.ca. The CRA confirms a reportable bare trust that is a listed trust doesn't file unless requested
canada.ca.
The nominee corporation is the case to watch. A corporation is not an individual, so the $250,000 test is gone, and a building is worth far more than $50,000. The partnership exception in 150(1.31)(d) only helps where each legal owner is itself a partner of a partnership that has to file a T5013.
Worked example: a probate joint account and the $250,000 test
Your client, 79, added his daughter to his investment account to keep it out of his estate. She holds as his agent and never uses the money. The account holds GICs and mutual fund units. It is worth $240,000 on January 1, 2026, and the market lifts it to $262,000 in November before it falls back to $248,000 on December 31.
| Test | Result |
|---|---|
| 150(1.31)(a): every legal owner also a beneficiary? | No. The daughter is on title but has no benefit |
| 150(1.2)(b): $50,000 or less throughout 2026? | No |
| 150(1.2)(b.1): trustees individuals, beneficiary related, listed assets only? | Yes. A person is related to himself, and the daughter is related to him |
| 150(1.2)(b.1): $250,000 or less throughout 2026? | No. The November peak is $262,000, $12,000 over |
| Outcome | Reportable bare trust, not listed: T3 and Schedule 15 due March 31, 2027 |
The year end value of $248,000 doesn't save it, because the test reads "throughout the year." Had the account stayed at or under $250,000 every day of 2026, it would be a listed trust and file nothing unless the CRA asked. Swap the GICs for shares of a private family company and the $250,000 test fails on the asset list, at any value above $50,000.
What to do with client files now
Nothing is owed for 2024 or 2025, so there are no late returns to clean up. The work is for the 2026 year, and some of it has to happen before December 31, 2026.
Build a list of every client arrangement where the name on title and the person who benefits differ: nominee corporations, probate joint accounts, accounts held for children, parents on title. Run each one through 150(1.31), then through the listed trust tests, and track fair market value through the year rather than at year end. For the ones that will file, collect Schedule 15 data now: name, address, date of birth, country of residence and taxpayer identification number for each trustee, beneficiary, settlor and controlling person canada.ca.
Know the penalties before you advise a client to skip a filing. A person who doesn't give their SIN or other identifier to the filer can face a $100 penalty under 162(6). A false statement or omission made knowingly or through gross negligence can cost the greater of $2,500 and 5% of the highest fair market value of the trust property in the year under 163(5) canada.ca.
Sources
Does the $50,000 or $250,000 test use the year end value?
No. Both tests in 150(1.2) require the value to stay at or under the threshold throughout the year, so a single day over the line fails the test for that year laws-lois.justice.gc.ca.
Are aunts, uncles, nieces and nephews related for the bare trust tests?
Yes. Subsection 150(1.32) adds aunts, uncles, nieces and nephews to the related persons for section 150, and says a person is related to himself or herself laws-lois.justice.gc.ca.
Is a joint account between spouses a reportable bare trust?
Not when each spouse is both a legal owner and a beneficiary and no one else is on the account. That is the 150(1.31)(a) exception, and the CRA's FAQ walks through a spousal joint investment account that files nothing for 2026 canada.ca.
Who reports the income from property held in a bare trust?
The beneficial owner reports it on their own return, as before canada.ca. The T3 and Schedule 15 only disclose who the trustees, beneficiaries and controlling persons are.
General information for the tax year shown, not advice for a specific client. Confirm the facts before you file or remit.