What Information Is Reported on Schedule 15 for Trusts in Canada?

If you are a trustee preparing a T3 return, Schedule 15 is the part that asks who is behind the trust. It can feel intrusive, and gathering the details from beneficiaries or settlors often takes longer than the form itself.

This article walks through who is covered, what details are requested, what to do when you cannot identify someone, and what can go wrong if the schedule is incomplete.

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

What Schedule 15 is

Schedule 15 is the Beneficial Ownership Information of a Trust schedule, filed with the T3 return. It applies to trusts that must file a T3 under the enhanced reporting rules. A trust that is not required to file has nothing to file.

For taxation years ending in 2025, CRA does not expect bare trusts to file a T3 return, including Schedule 15. Reportable bare trusts are subject to the trust reporting rules for taxation years ending on or after December 31, 2026, so the first returns are for the 2026 year.

Whether a trust must file a T3 depends on the type of trust. Under s. 150(1.2), 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. Another exception covers a trust where every trustee is an individual, every beneficiary is an individual related to each trustee (or a graduated rate estate of one), total fair market value is at most $250,000 at all times, and the assets are only listed low-risk types such as cash, GICs, listed securities and mutual funds.

The T3 return is due no later than 90 days after the trust's tax year-end. If that day falls on a weekend or CRA-recognized holiday, the next business day applies. A December 31, 2025 year-end is due March 31, 2026.

Who must be listed and what details are needed

Schedule 15 requests specified information on all trustees, settlors, beneficiaries and controlling persons. For each, you provide the following:

A settlor is the person who set up the trust by contributing property. In a family trust this is often a parent or grandparent, but it depends on who actually contributed the property.

When you cannot identify a beneficiary

Beneficiaries whose identity cannot be determined with reasonable effort may be described in Part C of Schedule 15. Make a genuine effort first and keep notes on what you did, since the allowance is tied to reasonable effort.

The reporting provisions in s. 150(1.1) to (1.3) do not require disclosure of information covered by solicitor-client privilege. If you think this applies, speak with a lawyer before leaving anything out.

Missing information and penalties

CRA says missing specified information, such as tax identification numbers, leaves the schedule incomplete and the trust has not met its filing obligations. A person who fails to give their tax identification number, such as a SIN, to the trustee may be liable to a $100 penalty under ITA s. 162(6) for each failure.

If the T3 or the Schedule 15 information is not filed by the due date, the late-filing 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 the CRA issued a demand to file and already assessed a late-filing penalty for any of the three preceding years, the penalty may instead be 10% of the unpaid tax 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 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.

What to do next

• Confirm first that your trust must file a T3 at all.
• List every trustee, settlor, beneficiary and controlling person.
• Ask each person for their address, date of birth, country of residence and tax identification number.
• Tell beneficiaries why you need the number, since the penalty can fall on a person who does not provide it.
• Record your efforts for any beneficiary you cannot identify.
• Carry forward information you reported before, but still file the schedule every year.

If the trust is unusual, has foreign parties, or you are unsure who counts as a controlling person, a lawyer or accountant can help before you file. If you are unsure whether a bare trust exists, CRA says that is a question of fact and suggests consulting a legal advisor.

Frequently asked questions