T3 Filing Deadline for Trusts and Bare Trusts in Canada

If you act as a trustee, the T3 deadline is one of the most important dates to know. For bare trusts, the answer has been unusual, because CRA has relieved them of filing for several years while new reporting rules were developed.

This article sets out the standard deadline, how it works for different year-ends, what the relief for bare trusts means in practice, and what happens if you miss a date.

This article covers Canadian federal tax law, which applies in every province.

The standard rule: 90 days after year-end

The T3 return is due no later than 90 days after the trust's tax year-end. Any balance owing is due within the same 90 days. If the due date falls on a weekend or a CRA-recognized holiday, the next business day applies.

For example, a December 31, 2025 year-end is due March 31, 2026.

Which year-end does a trust have?

Most trusts have a December 31 year-end. There are exceptions. A graduated rate estate can use a non-calendar year-end for up to 36 months after death, and a mutual fund trust can elect a December 15 year-end. Your deadline is counted from whichever year-end applies to your trust.

Not every trust has to file. A resident express trust must file a T3 unless a listed condition applies, such as existing less than three months or holding assets with a total fair market value not exceeding $50,000 throughout the year.

What the deadline means for bare trusts

For bare trusts, the date depends on the year. The table shows the position.

The first returns are for the 2026 year and are due 90 days after year-end, which is March 31, 2027 for a December 31, 2026 year-end. A reportable bare trust that is also a listed trust is not required to file unless it is requested to file.

The relief for earlier years is administrative. If CRA contacts you directly about a filing, get advice rather than ignoring the request.

Penalties for missing the deadline

• If the T3 or Schedule 15 information is not filed by the due date, the penalty is 5% of the unpaid tax when the return was due, plus 1% of that tax for each full month late, to a maximum of 12 months.
• If CRA issued a demand to file and already assessed a late-filing penalty for any of the three preceding years, the penalty may be 10% plus 2% for each full month late, to a maximum of 20 months.
• If the trust has no unpaid tax on the due date, the alternative penalty is $25 a day, with a minimum of $100 and a maximum of $2,500. A bare trust usually has no tax payable, so this is the likely penalty.
• A person who knowingly, or with gross negligence, makes a false statement or omission, or fails to file, for a non-listed trust faces a penalty of the greater of $2,500 and 5% of the highest fair market value of the trust property.

An incomplete Schedule 15 can also count as not meeting your filing obligations. Collect tax identification numbers well ahead of the date.

What to do next

• Confirm the trust's year-end
• Work out the due date by adding 90 days, and check for weekends or holidays
• Decide whether the trust must file at all
• If it is a bare trust, note that the first reportable year is 2026
• Gather Schedule 15 details for every person involved
• Ask a lawyer or accountant if you are unsure whether a bare trust exists

CRA says whether a bare trust exists is a question of fact, and suggests consulting a legal advisor if you are unsure.

Frequently asked questions