New Enhanced Reporting Requirements for Canadian Non-Profits

The federal government has recently released draft legislation related to the new enhanced reporting requirements by non-profits that were first announced in the 2024 Fall Economic Statement for consultation purposes. When the new requirements take effect, many non-profit organizations that were not required to make filings previously will now have to make filings.

Which organizations will be affected?

These changes will affect non-profit organizations, but will not affect registered charities, which are exempt from income tax under separate rules and file a different from, the T3010.

For the purposes of the Income Tax Act, a non-profit organization is any club, society or association that is organized for social welfare, civic improvement, pleasure or recreation or any other purpose except profit.

When will the new requirements take effect?

The new requirements will apply to fiscal periods that begin on or after January 1, 2026.

What are the new requirements for the annual return (T1044)?

Non-profit organizations will need to file the T1044, if they meet any one of the following four criteria:

the total of all passive income such as taxable dividend, interest, rentals, or royalties in the fiscal period exceeds $10,000;
the organization’s total assets at the end of the preceding fiscal period exceeded $200,000;
an information return was required to be filed by the organization for a preceding fiscal period; or
the total revenue in the fiscal period exceeds $50,000.

Criterion (d) above is the only change to this requirement.

What are the new filing requirements for small non-profit organizations?

Non-profit organizations that do not meet the above-noted thresholds for filing the T1044 will also be required to file a new, short-form return that contains basic information about the organization, including:

its business number or trust number;
the name of the organization and its mailing address;
the names and addresses of the directors, officers, trustees or similar officials;
a description of the organization’s activities, including whether it conducts activities outside Canada;
the organization’s total assets and liabilities and annual revenue; and
other prescribed information.

This new, short-form return for small non-profit organizations is completely new.

Takeaways

Non-profit organizations that are not required to file the T1044 currently should review the new criteria to determine if they will be required to do so starting in 2026.

Small non-profit organizations that are not required to file the T1044 would now need to file a new, short-form return starting in 2026.

Essentially, all non-profit organizations in Canada will be required to make filings starting in 2026, either the T1044 or the short-form return.

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This blog post is for information purposes only and is not a substitute for legal advice. Readers are cautioned to not rely on or take any action based on the information provided. If you have any questions regarding first-time home buyer exemptions, please reach out to James Struthers or Desmond Wang for a complimentary consultation. You can book a consult on www.macushlaw.ca through our booking system or call 604-900-7611.