INTRODUCTION
On January 15, 2026, the Charities Directorate of the Canada Revenue Agency (“CRA”) announced in its Quarterly Update (“Quarterly Update “) that it will discontinue its practice of providing pre-approval or automatic reviews of proposed amendments to a charity’s purposes or activities. This is a significant policy change by the CRA, which will place greater responsibility on charities to ensure compliance when making such changes, as well as considerably increase uncertainty for the charitable sector in this area.
CHANGES ANNOUNCED IN CRA’S QUARTERLY UPDATE
In the Quarterly Update, the Charities Directorate states that it will no longer provide pre-approval of proposed changes to a charity’s charitable purposes or activities “in the coming weeks” following the release of the Quarterly Update. As a result of this major policy change, the CRA makes clear that as a charity “grows and adapts,” it is the charity’s “responsibility to ensure it continues to operate exclusively for charitable purposes and carries out activities that further those purposes”.
In relation to the go-forward role of the CRA in these matters, the Quarterly Update indicates tat the Charities Directorate’s client services is “always available to provide general information if [a charity] needs help understanding whether something is charitable.” As well, the CRA will be providing“ a whole new suite of resources in the coming weeks” to help charities “navigate this process.” These new resources will include a refreshed guidance on charitable purposes, expanded model purposes, and a short guidance on how to draft appropriate charitable purposes. The exact timing of the release of these new resources has not been provided by the CRA at the date of this Bulletin.
Under the new policy, if a charity makes changes to its purposes, this must be done by formal updates to its governing documents. Once the changed purposes are adopted, the charity is to send the CRA a copy of its updated governing documents. In addition, if a charity updates its activities, the charity is “encouraged” to provide the CRA with an updated statement of activities.
The Quarterly Update stresses that these filings would keep their “file current” with the CRA, in order to “ensure … public information about [it] is accurate” and help the CRA better support charities to provide assistance upon request. To this end, the CRA continues to recommend charities submit updated governing documents or make any other changes by submitting them online through their CRA accounts and directs charities to the following page on its website on how to submit amended governing document.
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