CRA indicates that it no longer discards Sched. 15s that are not required, so that it will not subsequently assess penalties where a subsequent Sched. 15 states “no change”

CRA had been following the practice of discarding Schedule 15 information where that filing was not required. If the trust, for a subsequent year, filed a Schedule 15 for that year and indicated no change from the prior year, CRA would assess a penalty because no previous information existed on file.

However, CRA indicated that it paused this practice of discarding beneficial ownership information in 2024 in order to re-examine its position - and has now determined to process and retain Schedules 15 submitted voluntarily by a trust, including some of those submitted over the past two years.

Neal Armstrong. Summary of 2 June 2026 STEP Roundtable, Q.12 under Reg. 204.2(1).