Bill C-31, Budget Implementation Act, No. 2, 2026
The federal government introduced Bill C-31, the Budget Implementation Act, 2026, No. 2 (“Bill C-31”) in the House of Commons for First Reading on May 6, 2026. Bill C-31 sets out in legislative form the proposed measures initially introduced through the Department of Finance’s Notice of Ways and Means Motion tabled on May 4, 2026, by placing them before Parliament for consideration as part of the formal legislative process. Several of the proposed measures contained in Bill C-31 were previously announced in the 2025 Federal Budget, which was discussed in greater detail in Charity Law Bulletin No. 534, and which remain the same as in the 2025 Federal Budget.
Foreign Charities
Of particular relevance to the charitable sector are amendments concerning registered foreign charities. Currently, certain foreign charities that have received a gift from the Government of Canada may be registered as qualified donees for a 24-month period. Bill C-31 proposes to extend this registration period from 24 months to 36 months. The proposed amendments would also introduce a new annual information return filing requirement for registered foreign charities.
Bill C-31 also proposes to establish a more detailed statutory framework governing registered foreign charities, including provisions relating to registration, suspension, penalties, revocation, public disclosure, and compliance obligations under the Income Tax Act. In particular, the amendments would require registered foreign charities to file an annual information return within six months after the end of each taxation year, and would permit the Minister to make certain prescribed information from those returns available to the public.
Administrative and Compliance Measures
As well, Bill C-31 also contains broader tax administration and compliance measures that may affect charities and not-for-profits more generally. These include proposed amendments to the Income Tax Act concerning the Canada Revenue Agency’s (CRA) audit powers, foreign-based information requirements, compliance orders, notices of non-compliance, and related penalty and enforcement provisions. Among other changes, Bill C-31 would permit the CRA to require certain foreign-based information or documents to be provided within specified time periods, expand the circumstances in which the CRA may seek compliance orders from the courts, and introduce notices of non-compliance in certain circumstances, together with related penalty and limitation period rules. For more detail in this regard, reference can be made to Charity Law Bulletin No. 534, linked above.
Ontario Bill 119, the Protecting Ontario’s Streets and Communities Act, 2026
Ontario Bill 119, the Protecting Ontario’s Streets and Communities Act, 2026, was introduced for first reading on May 25, 2026. Schedule 8 of Bill 119 proposes amendments to the Police Record Checks Reform Act, 2015 concerning organizations that may be authorized to receive criminal record information for the purpose of conducting vulnerable sector checks. At present, vulnerable sector checks in Ontario must generally be completed by local police services. If passed, Bill 119 would create a process for certain other persons or entities to be designated as “authorized bodies” to carry out vulnerable sector checks.
Under the proposed amendments, a chief of police, or a designated member of a police service, would be permitted to apply to the Minister of Community Safety and Correctional Services (the “Minister”) for another person or entity to be designated as an “authorized body.” In practical terms, this designation would allow the person or entity to be treated as an “authorized body” under the federal vulnerable sector check process in section 6.3 of the Criminal Records Act (Canada), although Bill 119 does not itself specify which persons or entities would qualify or how designated bodies would operate in practice. The proposed amendments would also authorize regulations concerning eligibility requirements, application procedures, reporting obligations, and the amendment or revocation of designations.
Bill 119 does not specify which persons or entities would qualify for designation as “authorized bodies”. Instead, the proposed amendments would define an “eligible body” for designation as a person or entity specified in future regulations. As a result, the practical impact of Schedule 8 to Bill 119 is not yet fully clear from the Bill alone. Organizations that regularly require vulnerable sector checks may want to monitor the development of regulations under the Police Record Checks Reform Act, 2015 if Bill 119 is enacted. Schedule 8 would come into force on a day to be named by order of the Lieutenant Governor in Council.