Form T1441: How to Report Grants to Non-Qualified Donees

Form T1441: Reporting Grants to Non-Qualified Donees
Dov Goldberg

By Suzanne Goldberg, LGC

Since June 2022 Canadian registered charities have been able to make grants to organisations that are not qualified donees, and the T3010 reports those grants in two different places depending on size. Grants above a threshold go on Form T1441, grant by grant. Grants below it are summarised on the return itself. Getting the split wrong is easy, because the threshold is applied per grantee rather than per grant. This guide covers where the line falls and what each route requires.

What is a grant to a non-qualified donee?

It is a qualifying disbursement to an organisation that cannot issue official donation receipts, made under rules that took effect on 23 June 2022. Before that date, a Canadian charity could only work through its own activities or gift to qualified donees.

A non-qualified donee is any organisation that is not on the qualified donee list. Local community groups abroad, unincorporated associations, and social enterprises without charitable registration are typical examples.

Making a grant is different from carrying on your own activities through an intermediary. That distinction determines which rules apply and where the money is reported. If a partner acts on your behalf under your direction, that is your own activity and belongs on Schedule 2.

CRA sets out its administrative approach in Guidance CG-032. Accountability requirements attach to grantmaking, and the reporting below assumes those are already being met.

When is Form T1441 actually required?

Form T1441 is required where the sum of grants made to any one grantee totalled more than $5,000 during the fiscal period. The test is per grantee, cumulative across the year, not per grant.

This is where charities go wrong. Four grants of $2,000 to the same organisation total $8,000 and cross the threshold, even though no single grant came close to it.

Question C16 at line 5840 asks whether you made a qualifying disbursement by granting to a non-qualified donee, and covers grants inside and outside Canada. If you answer yes, you complete lines 5841, 5842 and 5843.

Line 5841 is the yes or no on whether any single grantee received more than $5,000 in total. Answering yes there means Form T1441 is required.

How are smaller grants reported instead?

Grants to a grantee totalling $5,000 or less are reported in summary on the return itself, at lines 5842 and 5843. They do not appear on Form T1441 at all.

Line 5842 is the number of grantees who received $5,000 or less in total. It is a count, not a dollar figure. Line 5843 is the total amount given to that group.

CRA's own example is worth working through.

Grantee Grants during the period Total Reported where
ABC $1,000 and $2,000 $3,000 Lines 5842 and 5843
DEF $2,000 and $4,000 $6,000 Form T1441, each grant on its own line
GHI $1,000 $1,000 Lines 5842 and 5843
JKL $2,000 $2,000 Lines 5842 and 5843

In that example line 5842 is 3, for ABC, GHI and JKL, and line 5843 is $6,000, being the sum of their grants. DEF goes on Form T1441 with both of its grants listed separately.

Note that the $6,000 at line 5843 and the $6,000 given to DEF are coincidentally the same figure in CRA's example. They are unrelated totals.

What does Form T1441 ask for?

One line per grant, not per grantee, with the grantee's name repeated as often as needed. A grantee that received three grants appears three times.

Field What to enter
Number of grantees At the top of the form, those that received more than $5,000 in total
Name of grantee The full name of the non-qualified donee
Purpose of grant A concise description, such as to pay for teachers' salaries or to purchase equipment for a new medical centre
Amount of non-cash disbursements Fair market value in Canadian dollars. Examples include land, artwork, equipment and pharmaceuticals
Amount of cash disbursements In Canadian dollars, valued at the time of the expenditure
Country where grant activities are carried on Country codes, if outside Canada. Multiple countries in alphabetical order, separated by commas

Include all grant resources disbursed during the period, even if the grant activities are not yet complete. The trigger is disbursement, not completion.

The purpose field rewards specificity. A description that connects the grant to your own charitable purposes is more useful than a generic phrase.

Where do these amounts sit on the rest of the return?

Line 5045 is your total grants to non-qualified donees, and it sits outside your own expenditure total. It should include every cash and non-cash grant reported in Section C and on Form T1441.

Line 5100 totals lines 4950, 5045 and 5050. Grants therefore run parallel to your operating expenditure, not inside it. A grant coded into programme costs at line 5000 breaks the return.

Amount Return line Form
Grants to non-qualified donees 5045 T1441 where any grantee exceeded $5,000
Gifts to qualified donees 5050 T1236
Your own charitable activities 5000 Schedule 2 if carried on outside Canada

Grants to non-qualified donees are qualifying disbursements and count towards your disbursement quota. The quota test totals line 5000, line 5050 and line 5045, then subtracts any designated gifts. Grants to non-qualified donees are never designated gifts, so line 5045 counts in full. A separately approved reduction to the quota, reported at line 5750, can also affect the amount you are required to spend.

What should your books look like if you make grants?

Grants need their own expenditure account and a grant register that carries everything Form T1441 asks for. Building the form from bank payments at year end is where errors enter.

The register should hold, for each disbursement: grantee name, date, amount, cash or non-cash, fair market value basis for non-cash, purpose, country, and the running total for that grantee in the fiscal period.

That running total is the important column. It is what tells you, in month nine, that a fourth small grant to the same organisation has crossed the $5,000 line and changed your reporting obligation.

Keep the running total by grantee rather than by project. A grantee funded through two separate programmes is still one grantee for the $5,000 test, and a register organised by project will not show you that.

Grantmaking also carries accountability obligations beyond reporting. The Act requires documentation, including the purpose of the grant, and records showing the resources were used for that purpose. CRA recommends a written grant agreement for most grants, particularly those above $5,000 or made on a recurring basis, but a formal agreement may not be necessary for a one-off grant of $5,000 or less in low-risk circumstances. Those records support the return without forming part of it.

One narrow exception applies to the form. Certain religious organisations that existed on 31 December 1977, have never issued official donation receipts and have never received gifts from a receipting registered charity do not have to fill out the amounts of grants to non-qualified donees on Form T1441, but only with written confirmation from the Charities Directorate.

If your charity has moved into grantmaking recently, the ledger structure and the register are worth setting up properly at the outset. That is the kind of thing ongoing bookkeeping support should establish rather than retrofit.

Frequently Asked Questions

Is the $5,000 threshold per grant or per grantee?

Per grantee, totalled across the fiscal period. Several small grants to one organisation are added together. This is an easy point to miss and it changes which reporting route applies.

Do grants below the threshold need any reporting?

Yes, in summary. Line 5842 is the count of grantees that received $5,000 or less, and line 5843 is the total amount to that group. They also form part of line 5045.

We granted to an organisation that later got charitable status. Which form?

Report according to the recipient's status at the time of the grant. If it was not a qualified donee when the disbursement was made, it is a grant to a non-qualified donee for that period.

The grant project has not finished. Do we report it now?

Yes. Report all grant resources disbursed during the fiscal period, even where the activities are not yet complete. Reporting follows the disbursement, not the outcome.

Do grants to non-qualified donees count towards our disbursement quota?

Yes, and in full. They are qualifying disbursements alongside your own charitable activities and gifts to qualified donees. Designated gifts are backed out of the test, and a grant to a non-qualified donee is never a designated gift. A separately approved reduction reported at line 5750 can also affect the required amount.

What if a grantee operates in more than one country?

Enter each country code, in alphabetical order, separated by commas. CRA's example format pairs the code with the country name, and residual regional codes cover countries not listed individually.

Grantmaking to non-qualified donees carries accountability requirements set out in CRA Guidance CG-032 that go well beyond the reporting described here. This article covers T3010 reporting as at August 2026 and is not advice on any particular grant arrangement.