CRA changes pre-approval process for charity purposes and activities
From filing an annual T3010 Registered Charity Information Return to meeting disbursement quotas, maintaining regulatory compliance is an ongoing—and often cumbersome—challenge for registered charities in Canada. One of those requirements includes stating (and updating) the charity’s purposes and activities, which must continually qualify as ‘charitable’ under Canada Revenue Agency rules (based on Income Tax Act and common law definitions).
To satisfy those rules, the organization must conduct activities that fall within one or more of the following categories:
- Advancement of education
- Relief of poverty
- Advancement of religion
- Delivery of a community benefit that the courts have defined as charitable
If its stated purpose or activities are amended or expanded—in a situation where that purpose is older and no longer considered charitable at law, for example—the registered charity must formally update its governing documents in writing. The CRA defines ‘activities’ as a charitable organization’s “… programs or the things you do to accomplish your purposes. Charitable activities are activities carried out to fulfill a charitable purpose. Without a charitable purpose, your organization cannot have charitable activities.”
Until this year, the CRA allowed a charity to seek pre-approval when making purpose and activity changes to ensure they maintained ‘charitable under law’ status. But in January 2026, the agency ended its pre-approval and automatic review process. This is a significant change for registered charities, which must now amend governing documents and then send them to the CRA for record-keeping purposes when revising purposes or activities.
For charities with larger and more specialized teams—or access to the services of lawyers or Chartered Professional Accountants with charity and non-profit sector compliance expertise—the change simplifies a purpose update process that in the past could take as long as four months to complete, involved the preparation of a written pre-approval request and required a meeting of a charity’s board members (or the passage of a written resolution) to approve amendments to the organization’s governing documents. Once those steps were complete, the charity was required to send a copy of the new purposes to the CRA. In that sense, the easing of this administrative burden could afford some charities greater flexibility in fulfilling their updated mission statements and delivering improved services to enhance their communities.
However, the risk is greater for smaller charities with limited financial resources. Rather than automatically reviewing any purpose amendments to determine whether they would remain charitable under law, the CRA will now assess amendments only during audits or compliance reviews. Charities that implement purpose and activity changes must now self-assess compliance, placing additional responsibility on the organization’s leadership and substantially increasing legal risk in the event of a future CRA challenge. This could also give some leaders pause before expanding their organization’s activities to better meet the needs of stakeholders. To make matters more complicated, a review by the agency might only happen years after a change of purpose has been implemented, thereby placing an organization’s charitable status at risk long after it has begun new activities.
The CRA’s guidance since making this procedural change has been vague. As a best practice, charities are encouraged to provide an updated statement of activities to the CRA once they have been adopted. Notably, the agency has not confirmed how it will manage situations where amended purposes are deemed non-charitable.
How should charity leaders proceed given this uncertainty? The CRA is promising updated guidance and support from its Client Service agents, but the most practical approach is to seek qualified legal counsel when implementing any change of purpose or activities. Even though charities bear full responsibility for ensuring legal compliance, expert advice will help to mitigate risk and allow an organization to focus on its mission statement—all while helping to alleviate the threat of a future revocation of charitable status.
Cecily Huang, Partner
For more information on changes to the Canada Revenue Agency pre-approval process for charity purpose and activity amendments, contact a member of the KRP LLP team today.
