Bill C-12 Border Act Receives Royal Assent
Bill C-12, the Strengthening Canada’s Immigration System and Borders Act, received Royal Assent on March 26, 2026, after completing third reading in the Senate on March 12, 2026, and subsequently being returned to the House of Commons for consideration of amendments made by the Senate. The Bill advances key anti-money laundering and financial transparency measures, including stronger penalties under Canada’s AML/ATF regime, and reflects the Federal Government’s effort to move forward with certain priority reforms affecting charities and not-for-profits (NFPs).
Bill C-12 was introduced on October 8, 2025, in response to significant debate surrounding Bill C-2, the Strong Borders Act. Rather than replacing Bill C-2, Bill C-12 extracts and fast-tracks certain undisputed provisions – particularly those relating to anti-money laundering and financial enforcement – while allowing more time for Parliament to consider more contentious elements of Bill C-2. The Federal Government has indicated that overlapping provisions would be removed from Bill C-2 to avoid duplication should both bills ultimately be enacted. This dual-track approach is intended to ensure that urgent measures, such as those addressing money laundering, can proceed without delay. For charities and NFPs, the most relevant aspect of Bill C-12 is the continuation of the anti-money laundering and financial transparency measures, including stronger penalties under Canada’s AML/ATF regime.
As previously reported in the June 2025, August 2025, and October 2025 Charity and NFP Law Updates, the Federal Government introduced Bill C-2, the Strong Borders Act, on June 3, 2025, proposing amendments to laws related to immigration, anti-money laundering and border security. Some of the amendments included new restrictions on large cash donations and granting the Canada Border Services Agency (CBSA) and law enforcement agencies broader powers to investigate money laundering, organized crime and terrorist financing. These amendments attracted significant debate and public attention given the extent of proposed new enforcement powers. The Bill has remained in second reading in the House of Commons, where it was last debated on September 17, 2025. Although it has not progressed further, Bill C-2 remains a possibility and still includes the proposed legislation to prohibit accepting cash donations of $10,000 or more. As discussed in the October 2025 Charity and NFP Law Update, this would make it an offence for charities and other entities that solicit public donations to accept large cash payments.
In summary, the developments around Bill C-2 and Bill C-12 are indicative that the Federal Government intends to shift toward stronger financial transparency and anti-money laundering enforcement, with proposed measures that could directly affect charities and NFPs. While Bill C-12 is already pushing forward key AML/ATF measures, it remains to be seen what will come of Bill C-2 which, if passed in the future, could introduce more operational challenges for charities.
Federal Government Pushes Forward with Bill C-9
Bill C-9, An Act to amend the Criminal Code (hate propaganda, hate crime and access to religious or cultural places), passed first reading in the Senate on March 26, 2026 after having passed third reading in the House of Commons the previous day on March 25, 2026.
As discussed in the September 2025 Charity & NFP Law Update, the Bill introduces the Combatting Hate Act, which proposes amendments to the Criminal Code aimed at protecting identifiable groups and places of worship. Among other measures, the Bill would create new offences, including prohibiting the wilful intimidation or obstruction of individuals seeking to access places of worship, as well as the intentional promotion of hatred against identifiable groups in public through certain symbols.
The Bill’s passage through the House of Commons followed a contentious process. The federal government secured sufficient support for the Bill during third reading through an agreement that included the addition of a clause proposing to repeal subsection 319(3)(b) of the Criminal Code. This subsection currently includes an exemption for hate speech in the case that a person, in good faith “expressed or attempted to establish by an argument or an opinion on a religious subject or an opinion based on a belief in a religious text.” The proposed repeal of that subsection was not included in the Bill as originally introduced.
The inclusion of this proposed repeal has generated significant debate. Various stakeholders, including religious and civil liberties groups, expressed concern that removing the exemption could have implications for freedom of religion and expression. In response, the federal government maintained that the proposed amendments would not criminalize legitimate expressions of faith.
At the time of writing, Bill C-9 remains subject to review by the Senate, which may study the legislation and propose amendments before it can receive Royal Assent and become law. As such, the final form of the legislation remains uncertain at this time.
Bill C-15, Budget 2025 Implementation Act, No 1, Receives Royal Assent
As noted in the November 2025 Charity & NFP Law Update, the federal government introduced draft legislation following the release of the 2025 federal budget on November 4, 2025. Bill C-15, Budget 2025 Implementation Act, No. 1 (“Bill C-15”) was introduced in the House of Commons on November 18, 2025, and finally received Royal Assent on March 26, 2026. Notably, the provisions relevant to charities and not-for-profits remain unchanged from those included at first reading.
As discussed in Charity & NFP Law Bulletin No. 534, the federal budget contained many provisions relevant to charities and not-for-profits. While Bill C-15 does not implement all budget measures, it includes, among other things: amendments to the AML/ATF regime, enhanced access to funds deposited by cheque and amendments to the Customs Tariff to implement a pilot for donated goods that allows for duty drawback paid for certain goods when they are donated to a registered charity under the Income Tax Act in certain circumstances.
Charities and not-for-profits should review these changes to determine whether they affect financial operations or compliance obligations.
House of Commons Finance Committee Launches 2026 Pre-Budget Consultations
The House of Commons Standing Committee on Finance has commenced its annual pre-budget consultations in advance of the 2026 federal budget, and is inviting input from Canadians and organizations on federal spending priorities according to a March 2, 2026 News Release. As part of the federal government’s transition to a fall budget cycle, the pre-budget consultation process was consequently commenced in the spring. This revised timing is intended to provide Canadians and organizations with sufficient time to participate and to ensure that their input is considered before the federal budget is presented in the fall.
Written briefs must be submitted online no later than April 30, 2026, at 11:59 p.m. (ET). Submissions are limited to 2,000 words, inclusive of all content, including graphs, quotations, images, and footnotes, and only one submission per organization or individual will be accepted. Following translation, briefs will be posted on the committee’s website. For charities and not-for-profits, the pre-budget consultation process provides an opportunity to raise sector-specific priorities and concerns for possible inclusion in the Committee’s report to Parliament on the 2026 federal budget.