1. Regulatory summary and penalty landscape
Understanding mandatory e‑filing: who, what, and when
As of 2026, Canadian federal regulations Canada.ca: Mandatory electronic filing for tax preparers require most tax preparers to electronically file T1, T2, and T3 returns for clients if they prepare more than five of any return type annually. Exemptions are rare; the vast majority of accounting firms and tax businesses now fall under mandatory e‑filing rules. This requirement applies regardless of software or firm size.
Penalty structures: amounts and triggers
- T1 and T3 (individual/trust): $25 penalty per non-electronically filed return.
- T2 (corporate): $100 penalty per paper-filed return.
- Amended T1 returns: If paper-filed or printed and mailed, still count as paper-filed for non-compliance calculations.
- EFILE/ReFILE is available each year for a prescribed filing window Canada.ca: EFILE for electronic filers.
Higher late-filing penalties ($100s–$1,000s based on outstanding tax) under ITA s.162(1)–(2) Justice Laws: Income Tax Act, Section 162 are separate and can apply in addition to e-file penalties if a return is filed after deadline.
Recent changes and expansion
- Firms preparing more than five returns of a type—down from 50 for many slips and reporting forms Finance Canada: ITA Amendments.
