New Bare Trust Reporting Rules Coming in 2026

New rules designed to increase transparency around the beneficial ownership of assets held through bare trust arrangements will apply to taxation years ending on or after December 31, 2026.

A trust arrangement generally arises when the registered owner of an asset holds legal title on behalf of another person or entity—the beneficial owner. When the registered owner has little or no independent authority or discretion over the asset, the arrangement may be considered a bare trust.

Historically, bare trusts were generally not required to file a T3 Trust Income Tax and Information Return. Beginning in 2026, however, a bare trust that exists at any time during the year may be required to file a T3 return and Schedule 15, even if the trust has no income.

While certain exceptions may apply, these new rules may bring many arrangements that were previously outside the trust reporting requirements into the filing regime.

Individuals and businesses should review their ownership arrangements to determine whether they may have a bare trust reporting obligation for 2026 and subsequent years. Failure to comply with the new requirements may result in penalties and other consequences.