Goodbye, 2025: when it came to big announcements, 2025 was a relatively underwhelming year for Canada’s charities and non-profits. But what will 2026 hold for the sector? Below, we highlight four developments to keep an eye on in 2026. Already, two of these—the CRA’s move to “axe the fax” and the Lobbying Commissioner’s move to lower the registration threshold for organizations—are well underway.

1. How will changes at the CRA affect its services for charities?

The last few months have already seen several noteworthy changes and headlines affecting the Canada Revenue Agency:

  • in Budget 2025, Ottawa plans to cut the CRA’s budget over the next four years by ~$4.1 billion, and to reduce the federal public service generally to 333,000 employees by 2029 (without specifying where the job cuts will take place);
  • the CRA continues to implement its 100-day Service Improvement Plan (which it had developed and launched between September 2 to December 11, 2025) to resolve recent service issues; and
  • the Charities Directorate (the “Directorate”) is retiring its fax line.

The last of these developments—the Directorate’s gradual phasing out of fax—affects charities directly this month.

The decision to “axe the fax” is part of the CRA’s larger plan to transition its services to a digital-by-default environment, consistent with the Government of Canada’s Digital Standards.

Charities and the public can still send physical mail, but the Directorate is strongly encouraging everyone to set up a CRA online account through which users can submit applications, file T3010s and supporting materials, and make requests for changes.  

The fax machine might seem like a relic in 2026, but thousands of charities and Canadians still depend on fax to communicate with the CRA. Fax is also accessible (ask older/rural Canadians), secure (ask a bank), and arguably “green” as well (see: digital faxing).

Many in the sector continue to rely on fax as their preferred means of communicating with the Directorate partly because of the real difficulties they had experienced when they tried to open a CRA online account or complete a charitable registration application online.

It should be noted that, for now, charities appear to be relatively unaffected by the CRA’s 100-Day Service Improvement Plan (the “Plan”)—at least on paper. Charities were barely mentioned in the CRA’s December 11th news release. Even before the Plan, the Directorate had been largely achieving its service standards, such as responding to complex written enquiries from charities within 120 days and routine ones within 45 days (which it did, at least 75% of the time, in 2024-25) or responding to charitable applications within six months (which it did, at least 96% of the time, in 2023-24).

The Plan may ultimately have positive spillover effects for charities—and these spillover effects could translate into marked improvements to CRA’s online systems and portals, just in time for orphaned fax users to adopt them. But will Ottawa’s planned budget cuts to the CRA threaten to undo this progress, hobbling CRA’s ability to serve the sector? It is a storyline worth watching.

2. Which non-profits will be exempt from the revised NPO reporting rules?

January 1, 2026 was supposed to be day one for when Ottawa’s new non-profit reporting requirements would have gone into effect.

Had those new rules been in force, all Canadian non-profit organizations (NPOs) would have a reporting requirement for the 2026 tax year, regardless of whether they have any revenues.

This all changed with Budget 2025, which delayed the new reporting requirements and postponed their start date to 2027 (or possibly beyond).

In Budget 2025, the federal government announced that it is reviewing the feedback it had received and that it will “release final proposals in due course”.

The final proposals, Ottawa says, will “minimize any additional administrative burden and clarify which organizations are, or are not, subject to the new reporting requirements”.

We have not seen the revised rules (which will be released this year if Ottawa wishes to target a 2027 start date) but the federal government’s intended course correction is a welcome announcement.

Under Canada’s tax system, NPOs are clubs, societies, or associations that are not charities but that are organized and operated solely for non-profit purposes (like recreation or civic improvement). NPOs include incorporated and unincorporated bodies.

Ottawa’s stated goal of increasing transparency in the NPO sector may be laudable. But, as some have fairly questioned, is it really necessary or reasonable to compel every NPO (think: your book club) to file a tax return annually and to provide information about its directors, assets, and revenues (even if they have none of these), all at the risk of penalty?

Will your book club ultimately be spared under the final proposals? Hopefully, yes. But, just like with the contents of the final proposals themselves, it is still anyone’s guess.

3. Will advocacy groups curb their lobbying activities—or register as lobbyists?

New rules took effect on January 19, 2026 that will likely result in more charities and NPOs having to register under the federal Lobbying Act. 

Specifically, the minimum number of hours that an organization’s employees must spend on lobbying activities to trigger registration is dropping from 32 hours to eight.

Under the Lobbying Act, an organization must register in-house lobbyists (i.e. employees who communicate with federal public office holders on behalf of their employer) only if the total time that its employees spend on lobbying activities would, had it been performed by one employee, represent a “significant part of the duties” of that one employee.

Historically, the Office of the Commissioner of Lobbying has considered the phrase “a significant part of the duties” to mean 20% or more of an average employee’s work hours in any given four-week period—or 32 hours in a month, based on a 40-hour work week.

On June 16, 2025, the Commissioner issued a new interpretation bulletin that redefines and lowers the “significant part of the duties” threshold.   

Starting January 19, 2026, an organization must register in-house lobbyists when the total amount of time that all employees in the organization spend on lobbying activities, in the aggregate, is eight hours or more in any four-week period.

Charities and NPOs should note that lobbying activities include not only direct communications with public office holders, but also any time spent preparing for such communications or making grassroots appeals.

Advocacy organizations that had toed the 32-hour threshold in the past will need to consider whether to reduce their lobbying activities dramatically—or register.

The new eight-hour threshold is not hard to meet. If one employee spends an entire workday on lobbying activities, or if four employees each spends two hours on lobbying activities in a given month, the registration requirement will be triggered.

4. What surprises might Ottawa introduce when it finally enacts its previous tax proposals?

Unlike in 2025, there were several noteworthy announcements for the sector in 2024, particularly in Budget 2024, where Ottawa had proposed several significant changes to the Income Tax Act. These changes included:

  • boosting the CRA’s audit powers so that the agency can issue notices of non-compliance (with monetary penalties) and compel representatives of a taxpayer to answer questions and provide documents under oath;
  • cutting back on the content required to be shown on official donation receipts;
  • allowing the CRA to provide notices (such as revocation notices) to charities electronically, where it was previously required to send notice by registered mail; and
  • extending the qualified donee status for eligible “foreign charities” from 24 to 36 months.

Most of these changes directly affect charities in a big way. So, it might come as a surprise to many that these changes have not yet been enacted, and that the legislation for these measures remains in draft form.

Budget 2025 confirmed that Ottawa would be moving ahead with these previously announced measures. However, Ottawa also signaled that it would implement these measures “as modified to take into account consultations and deliberations since their release”. No specifics were provided regarding the nature of these modifications.

We do not expect that the government will wait another year before enacting these measures that had been tabled two years ago. But astute charities and non-profits will not blindly assume that the 2026 version of these proposals will be carbon copies of 2024’s. They will be studying the text of the final bills carefully. We here at Miller Thomson will be watching, too.

Miller Thomson’s Charity & Not-For-Profit Law Group is a leading advisor and advocate to Canada’s charitable and nonprofit sector, helping entrepreneurs and organizations navigate and succeed in Canada’s regulatory environment.

Make it your resolution this year to stay ahead and on top of the changes discussed in this article—and other legal developments. Subscribe to our Insights today.