The federal government’s charitable sector “modernization” project appears to be broader than initially signalled.

On October 8th, the Department of Finance released a Consultation Paper inviting sector stakeholders to share their feedback on four key areas of charitable regulation. These four areas are:

(1) the charitable registration process;

(2) digital service delivery;

(3) audit and compliance; and

(4) revocation and objections.

Submissions are due by Thursday, December 3rd, 2026.

When the government first announced the modernization project in its Spring Economic Update and in the CRA’s quarterly update, the project appeared to be administrative rather than transformational, focusing more on service delivery and operational efficiency than on fundamentally rewriting Canada’s charitable framework.

The Consultation Paper goes further, posing questions about general reform, international frameworks, sanctions, the revocation tax, and even whether organizations revoked for serious non-compliance should be able to re-register.

Miller Thomson’s Charities and Not-For-Profit Group plans to make a written submission, and we would welcome your views.

What questions does the Consultation Paper ask?

The Consultation Paper contains more than 30 questions across the four focus areas.

The questions range from the very specific (e.g., “What practical steps could help charities provide more accurate, complete, and consistent information when completing the [T3010] return (for example, validation checks for online filing, clearer instructions, or better guidance)?”) to the more outward-looking (e.g., “What elements of reporting frameworks internationally should Canada consider adopting?”).

Some other questions that may interest sector stakeholders (or generate a spirited response from Canadians) include:

  • Is the online registration process for charities easy to use and, if not, what are the key problems?
  • Is CRA’s My Business Account service simple and user-friendly? Are there particular areas that need improvement?
  • What particular barriers do charities face in accessing the CRA’s digital services?
  • Should more information about the CRA’s audit and compliance activities be publicly available in order to increase transparency? If so, what additional information should be available and at what stage of the audit process?
  • Should the current objection timelines be changed to improve timeliness and reduce administrative burden?
  • Should the revocation tax continue to be reduced by disbursements to other charities?
  • Should the CRA continue to revoke organizations for failing to file their information return or should it instead use alternatives (e.g., monetary penalties, suspensions) to encourage organizations to file?
  • Should re-registration be available to organizations whose registration has been revoked for serious non-compliance or should the availability of re-applying for registration be more limited?

The Consultation Paper does not require contributors to respond to all questions.

The Consultation Paper also does not prohibit Canadians from sharing comments and ideas generally, so long as they relate to the four focus areas. Here, we note that many of the CRA’s questions in the Consultation Paper are also open-ended, such as what improvements can be made to the charitable registration process; whether there are any particular services that the CRA should offer for registered charities that are not currently available; what other regulatory approaches should the government consider to modernize and promote compliance with the charitable sector; and how the current processes around revocation (including the objection process) should be improved.

How can I make my voice heard?

We encourage Canadians across the sector to make their voices heard in this consultation.

Consultations on large-scale sector reform are hard to come by. For instance, as the government notes in the Consultation Paper, the legislative framework governing intermediate sanctions, revocations, and objections has not been comprehensively reviewed in over two decades.

As mentioned above, Canadians have until Thursday, December 3rd to share their feedback with Ottawa.

Canadians can provide their input by emailing [email protected]. Canadians doing so must enter the phrase “Modernizing the Framework for the Charitable Sector” in the subject line.

Alternatively, the public can share their comments with the Department of Finance’s Charities Section by sending regular mail to the address listed on this page.

Will Miller Thomson be making a submission?

In past consultations, Miller Thomson LLP’s Charities and Non-Profits Group has advocated for changes to how charities are regulated, drawing from our unique perspectives and expertise as charities lawyers, tax lawyers, estate planning lawyers, and gift planners. Many of our proposals have become law or been adopted as CRA administrative practice today.

Our group once again plans to prepare and submit a written response to Ottawa as part of this consultation.

To help us craft our submission, we welcome the views of readers, clients, subscribers, sector stakeholders, and the public more generally on the consultation questions.

Readers wishing to share comments with us are encouraged to email those comments to [email protected]. Those readers wishing to send comments anonymously to us may do so by completing this Google form.

Have a question about the Consultation Paper? Have a question about the government’s modernization project more generally? A lawyer from our Charities and Non-Profits Group would be pleased to answer your question. Please note: Miller Thomson LLP reserves the right not to include any public submissions in its own written submission to the Government of Canada and may use any submitted ideas, comments, or proposals without attribution.