On June 29, 2017, the Canada Revenue Agency (the "CRA") released a message for applicants seeking charitable registration and for charities seeking re-registration. As of July 1, 2017, the Charities Directorate will no longer review draft governing documents with charity applications. Applications submitted with draft governing documents will be treated as incomplete and returned to the applicant. The message indicates that a complete application must now include certified governing documents. Applications received by the Charities Directorate prior to July 1, 2017 will not be affected by this change.
With respect to applicants looking to amend their current purposes, the Charities Directorate will accept the proposed purposes, but applicants must also provide their current certified governing documents with their application. The Charities Directorate has indicated that this also applies to applicants seeking re-registration who have also amended their purposes. The message does not include similar relief for other changes to an organization's governing documents (e.g.: name changes, etc....).
This change will mainly affect organizations that have not yet incorporated and are waiting for the CRA's approval of their purposes before incurring incorporation fees. Charities that are already incorporated and are only looking to refresh their purposes should not be impacted by this change because the CRA will accept their draft purposes as long as their current certified governing documents are provided.
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