New Non-Profit Organization Reporting Requirements – Updated to April 28, 2026

The federal government continues to advance its initiative to expand information reporting requirements for non‑profit organizations (NPOs) in Canada.

Background

Following the initial draft released on August 15, 2025, the Department of Finance issued revised draft legislation on January 29, 2026, reflecting stakeholder consultations and refining the original proposals. These measures were first announced in the 2024 Fall Economic Statement and subsequently confirmed in Budget 2025.

Most recently, the Spring Economic Update tabled on April 28, 2026 confirmed the federal government’s intention to proceed with the January 29, 2026 draft legislation, subject to the normal parliamentary process. This expands reporting requirements for NPOs under paragraph 149(1)(l) of the Income Tax Act, and includes agricultural organizations, boards of trade and chambers of commerce under paragraph 149(1)(e).

Important: Registered charities and foundations are not included in these changes, as they are governed by separate reporting rules under the Income Tax Act.

Key Changes in the January 29, 2026 Draft Legislation

If enacted, the new reporting framework will generally apply to fiscal years beginning on or after January 1, 2027.

1. Expanded Filing Requirements for Form T1044

Currently, an NPO must file Form T1044 – Non‑Profit Organization Information Return if it meets any of the following criteria:

• Passive income exceeds $10,000
• Assets exceed $200,000 at the end of the preceding fiscal year
• The organization was required to file a T1044 in a prior year

The January 29, 2026 draft legislation introduces an additional threshold:

• Total amounts received (including capital receipts) exceed $100,000

This increase to $100,000 replaces the earlier $50,000 threshold proposed in August 2025 and reflects feedback from the sector.

2. Introduction of a New Short‑Form Information Return

A new short‑form annual information return will be required for NPOs that:

• Do not meet any of the T1044 filing thresholds, and
• Total amounts received exceed $10,000

Certain very small or loosely organized groups (for example, informal clubs that do not meet the definition of an “organization”) may be excluded, depending on the facts.

The short‑form return will require basic information, including:

• Description of activities (including whether any activities occur outside Canada)
• Total receipts, assets, and liabilities
• Names of directors, officers, trustees, or similar officials (addresses were removed from August 2025 proposal)

As with the T1044, the short‑form return will be due within six months of the organization’s fiscal year end.

3. A Three‑Tier Reporting Framework

The revised proposals establish a clearer three‑tier system:

1. T1044 return – for organizations meeting existing income, asset or historical filing thresholds, or the new annual receipts threshold (over $100,000).
2. Short‑form return – for smaller NPOs with receipts over $10,000 and up to $100,000.
3. No return – for smaller NPOs with receipts up to $10,000.

This structure aims to balance improved transparency with reduced administrative burden for the smallest organizations.

What NPOs Should Do Now

Non‑profit organizations, agricultural organizations, boards of trade and chambers of commerce, that currently rely on the income tax exemptions under paragraphs 149(1)(I) and (e), respectively, should:

• Review their annual receipts, and income and asset levels
• Determine whether they will be required to file a T1044 or the new short‑form return
• Begin preparing systems and processes to collect the required information
• Monitor further legislative developments as the bill proceeds through Parliament

Early preparation will reduce compliance risk once these measures come into force.

The T1044 and short form return are in addition to the corporate tax return (T2) required of all incorporated BC societies. See Tax Reporting Requirements for Non-profits in Canada

How Manning Elliott LLP Can Help

Our Manning Elliot NPO team can assist NPOs in assessing and assisting with their filing obligations.

If you have questions about how these changes for non profit organizations may impact your organization, please contact us.

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NOTE: Canadian tax laws are complex and subject to frequent changes. The contents of this Manning Elliott blog are not intended to represent legal or tax advice. Please consult your tax adviser before employing any strategies that may have been discussed within this article.