CRA EFILE Registration for Tax Preparers

Subsection 150.1(2.3) of the Income Tax Act states that a tax preparer shall file any return of income prepared by the tax preparer for consideration by way of electronic filing, except that five of the returns of corporations, five of the returns of individuals other than trusts and five of the returns of estates or trusts may be filed other than by way of electronic filing.

Filing electronically requires the Minister’s authority, which the Canada Revenue Agency grants through EFILE registration. Subsection 150.1(2.4)(a) refers to that authority directly, and to the criteria in subsection 150.1(2) that an applicant must meet.

Subsection 150.1(2.2) defines a tax preparer, for a calendar year, as a person or partnership who, in the year, accepts consideration to prepare more than five returns of income of corporations, more than five returns of income of individuals other than trusts, or more than five returns of income of estates or trusts, but does not include an employee who prepares returns of income in the course of performing their duties of employment.

Subsection 150.1(2.4) states that subsection (2.3) does not apply to a tax preparer for a calendar year in respect of a return of income:

• (a) of a type for which the tax preparer has applied to the Minister for authority to file by way of electronic filing for the year and for which that authority has not been granted because the tax preparer does not meet the criteria referred to in subsection (2)
• (b) of a corporation described in any of paragraphs 205.1(2)(a) to (c) of the Income Tax Regulations
• (c) of a type that the Minister does not accept by way of electronic filing

The definition in subsection 150.1(2.2) separately excludes an employee who prepares returns of income in the course of performing their duties of employment.

The Canada Revenue Agency publishes its own guidance on EFILE and on mandatory electronic filing, and that guidance is the friendlier read. Its pages could not be retrieved when this page was written, so rather than paraphrase them from memory we quote section 150.1 of the Income Tax Act on the Justice Laws Website, which is the Government of Canada’s own consolidation of the same rule and the source the guidance is written from.

We hold no entry for a provincial regime, including Quebec’s. That means we have not been able to read one, not that no requirement exists.

EFILE registration and its annual renewal are handled directly by the Canada Revenue Agency. The statutory rule itself is here:

• Income Tax Act section 150.1, Justice Laws Website (opens in a new tab)

Expat183 does not handle EFILE registration or renewal on anyone’s behalf. Registration is managed entirely by the Canada Revenue Agency.

This requirement appears in the regulatory requirements section of your professional dashboard when you have recorded a Canadian jurisdiction. If one of the Act’s published exceptions applies to you, you can record the requirement as not applicable and cite the paragraph you are relying on.

We record the exception you cite. We do not check it against the Canada Revenue Agency, and recording it here is not confirmation from the Agency that it covers you. Your declaration is a statement about your circumstances now, so we ask you to confirm it again each year.

Expat183 is a technology marketplace that connects users with legal, financial, and tax professionals. We do not provide legal, tax, or regulatory advice.

We report published regulatory requirements as a courtesy to help professionals stay informed. This is not advice, and professionals should always verify their filing position directly with the Canada Revenue Agency.

• Income Tax Act section 150.1, Justice Laws Website (opens in a new tab)