By Terrance S. Carter and Theresa L.M. Man

Following the introduction of the 2025 federal budget (“Budget 2025”) on November 4, 2025, the federal government has moved swiftly to introduce draft legislation to implement certain provisions set out in Budget 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 is currently in second reading.

As reviewed in greater detail in Charity & NFP Law Bulletin No. 534, as well as in an article published by the authors in Law360 Federal Budget 2025: Impact on charities and not-for-profits, Budget 2025 contained a number of provisions relevant to charities and not-for-profits. While Bill C-15 does not enact all provisions in Budget 2025, the following have been included in the draft legislation:

• Expanded reporting requirements for non-profit organizations;
• Amendments to Canada’s trust reporting regime;
• Amendments to the AML/ATF regime (including providing additional grounds for dissolution of corporations under the Canada Not-for-profit Corporations Act and Canada Cooperatives Act that are listed as terrorist entities under the Criminal Code);
• Enhanced access to funds deposited by cheque;
• 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; and
• Amendments to the alternative minimum tax (AMT) to exempt certain trusts for the benefit of Indigenous groups

Of note, Bill C-15 does not contain any provision concerning measures previously announced in a Notice of Ways and Means Motion on October 29, 2024, that was referenced in the 2024 Fall Economic Statement regarding disclosure requirements for some reproductive service charities. These measures, which are explained in greater detail in Charity & NFP Law Bulletin No. 534, were a source of concern for many in the charitable sector.   

​Read the November 2025 Charity & NFP Law Update