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New Reporting Obligations for CBCA Corporation Owners

New Reporting Obligations for CBCA Corporation Owners


Corporations incorporated under the Canada Business Corporations Act (CBCA) must now file their register of “Individuals with Significant Control” (ISCs) with the federal government.

What’s Changed?

Since June 2019, most businesses incorporated under the CBCA have been required to maintain ISC registers. As of January 22, 2024, these corporations must now file their ISC registers with Corporations Canada. CBCA corporations must update their ISC register at least once a year, and within 15 days of becoming aware of any changes affecting the register.

While businesses incorporated under the Ontario Business Corporations Act must maintain an ISC register, they are not required to file their ISC register with the provincial government.

Who’s an Individual with Significant Control?

An individual is an ISC if either of the below criteria are met:

  • The individual owns, controls or directs 25% or more of shares individually, jointly or in concert with one or more individuals;
    • This can be 25% or more of voting shares or 25% or more of all the shares based on the fair market value of the shares;
  • The individual has control in fact over the corporation without owning any shares.
    • “Control in fact” means that the individual has the power to affect the day-to-day management of the corporation.

What Information Needs to be Filed?

The following information for each ISC must be filed with Corporations Canada:

  • Full legal name;
  • Date of assuming/relinquishing significant control ;
  • Description of their control;
  • Address for service.

Additional details like date of birth, citizenship, and tax residency will be collected but remain confidential.

When does Information need to be Filed with Corporations Canada?

 ISC information must be filed by a corporation:

  • When filing the annual return;
  • Within 15 days of a change to the ISC register;
  • Upon incorporation or within 30 days of an amalgamation or continuance.


 A corporation that fails to file its ISC information with Corporations Canada may be subjected to the following sanctions:

  • Refusal of a Certification of Compliance;
  • The administrative dissolution of the corporation;
  • A fine of up to $100,000.

We’re Here to Help!

gbtlaw will continue to monitor these developments. Should you have any questions, please contact one of our business law professionals.

This blurb to highlight the differences in reporting requirements for CBCA and OBCA corporations.


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