We communicate directly with senior management of the CRA

EFILE Association of Canada

Formed in 1993, the EAC/ATC is a federally registered non-profit corporation, representing tax practitioners from all regions of Canada to senior management of the Canada Revenue Agency, Federal and Provincial Ministries of Revenue, as well as tax software providers.

Our membership consists of professionals and fully represents the Efile industry: from sole proprietors to large nationwide firms.  EAC/ATC members account for over one-third of all EFILED T1s in Canada.

What we do

One of the core functions of the EAC/ATC is to communicate directly with senior management of the CRA on behalf of members. As your conduit to the CRA, we meet regularly with senior managers of the CRA to discuss tax policy and administrative issues that affect all tax practitioners.

Over the years, the EAC/ATC has been successful in requesting changes to the EFILE system to facilitate the operation of a tax practice. Tax practitioners are the front line administrators of Canadian tax policy, and we are recognized as the professional association that senior management of the CRA turns to for industry comment and feedback.

We also produce and distribute our IMPACT Newsletter (published 3 times a year), providing important updates on developments within the tax and EFile service industry.  View a sample IMPACT Newsletter in the Library section of our website.  Previous editions of the IMPACT Newsletter are archived in the Library section and are available to EAC/ATC members.  Members also receive a copy of the annual EFiler’s Resource Guide.

The EAC/ATC is governed by a national 15 member Board of Directors elected by the membership of the EAC/ATC at the Annual General Meeting. Members of the Board of Directors serve renewable 3-year terms.

News

Bare Trust Filing Update

The CRA announced that it is once again holding off on requiring Canadians to file T3 tax forms for bare trusts (for tax year 2025).  You will recall the CRA first decided to pause the bare trust filing requirements in the middle of a chaotic 2024 tax filing season.

The CRA also indicated that once the agency has certainty about the proposed legislative changes (see press release below), the CRA will revisit the possibility of creating a return specific to bare trusts (as recommended by the Taxpayer’s Ombudsperson).

CRA Press Release – December 16, 2025

Proposed amendments related to trust reporting

On November 18, 2025, the Government of Canada tabled Bill C-15, An Act to implement certain provisions of the budget tabled in Parliament on November 4, 2025, with proposed amendments to the Income Tax Act (ITA) that relate to trust reporting.

Based on proposed legislation in Bill C-15, and consistent with the Explanatory Notes Relating to the Income Tax Act and Other Legislation published by the Department of Finance, the CRA does not expect bare trusts to file a T3 Trust Income Tax and Information Return (T3 return) including Beneficial Ownership Information of a Trust (Schedule 15) for taxation years ending in 2025. Certain bare trusts will be required to file for taxation years ending on or after December 31, 2026.

Among other proposed changes, for taxation years ending on or after December 31, 2025, certain trusts may not be required to file a T3 return if specific conditions are met. Where those conditions are not met and a T3 return is required to be filed, these trusts will not be required to file Schedule 15 with their T3 return for taxation years ending on or after December 31, 2025. These trusts include, but are not limited to:

* Trusts holding assets with a total fair market value (FMV) that does not exceed $50,000 throughout the year.

* Trusts holding only the specific asset types as outlined in proposed paragraph 150(1.2)(b.1) of the ITA for the applicable taxation year, with a total FMV that does not exceed $250,000 throughout the year, provided certain additional conditions are met.

* Specific client trust accounts holding only the specific asset types as outlined in proposed paragraph 150(1.2)(c) of the ITA for the applicable taxation year, with a total FMV that does not exceed $250,000 throughout the year.

* Trusts established to comply with a statute of Canada or a province where the persons acting as trustee hold the property in trust for a specified purpose, such as those of bankruptcy trustees or provincial guardians.

The CRA confirms that taxpayers may voluntarily file under current law, pending the enactment of Bill C-15. If the proposed legislative changes are not enacted, the CRA will provide further direction at that time.

CRA EFile Software Block security feature

Beginning in February 2026, the CRA will implement a process that associates EFILE accounts with specific certified T1 and T3 software products.

Once the Software Block is in place, if a T1 or T3 return is submitted using a different tax software product than the one linked to your EFILE account, the return will be rejected, and the transmission will fail.  You will be required to call your EFILE Helpdesk to sort it out.  The enhancement is designed to reduce fraud by strengthening the security of tax returns filed by ensuring that EFilers submit tax returns through the specific tax software product associated with their EFILE account.

The Software Block security enhancement applies to all years accepted by EFILE (tax years 2018 to 2025) and ReFILE (tax years 2021 to 2025).  You can associate more than one tax software to your EFILE account.  Application of this security feature will occur when you renew your EFILE account and will vary for existing EFILERS and new EFILERS.

During the 2025 renewal process for existing EFILE accounts, the CRA will automatically associate your EFILE account with your software product based on your historical usage.  If you wish to update or change your tax software product preferences at any time, you will need to contact your EFILE helpdesk.  Your EFILE account renewal indicates which EFILE helpdesk applies to you.

New EFILE registrants will be able to identify their preferred software products during screening with the EFILE helpdesk.

2025 Annual Survey of EFilers

Every year, after tax season, we survey tax preparers and request feedback on issues and irritants that hindered their work during the tax season.  This information forms the basis of our submissions to the CRA and our subsequent meetings with CRA senior management.  The survey is an opportunity for you to have your voice heard by CRA.

Thank you to everyone who completed the survey.  The response rate was very high.  The survey results were aggregated and provided to the CRA.

New Protocols for Authorizing a Representative

Beginning July 15, 2025, the method to Authorize a Representative to obtain access to client data via RAC was changed.

EFilers can no longer obtain online access to individual clients’ tax information by using the Authorize a Representative function via tax software and the EFILE service.  Instead, clients who want to provide you with access to their CRA account must take additional steps to authenticate you.

This is a significant change as it adds steps and greater client interaction to the authorization process.  However, the new protocols are driven by privacy and security concerns.  It’s a by-product of our time.  As tax preparers we play an important role in ensuring client information is protected, and CRA is obliged to obtain informed consent from the taxpayer before granting a representative access to their tax information.

Note that your current authorizations will not change.  The new process applies only to new T1 authorization requests.

Details of authorization options are available in our July 2025 IMPACT Newsletter, available in the library section of our website.