While the Charities Directorate, as a non-essential department of the Canadian Revenue Agency (“CRA”), is currently closed until further notice due to the COVID-19 crisis, many charities may need or want to make submissions to the Charities Directorate. For example, registered charities responding to an audit letter should still consider the original deadlines as valid. Registered charities may also consider changing their objects to allow them to better act in times of crisis such as these and request a change in purposes from the Charities Directorate. Further, applicants to become a registered charity responding to a request for more information should similarly follow the original deadline for submitting that information as effective. However, due to the Charities Directorate closure, not all forms of submissions will get through.

Currently, the best means for delivering responses to letter requests from the Charities Directorate is through regular mail. Couriers will be unable to deliver packages because there is no one there to accept the packages. Similarly, there is no one in the office to maintain the fax machines, so even if there is a record of the fax going through to the Charities Directorate, it is not likely to have been actually received by the Charities Directorate as the fax machine has limited memory and not enough paper.

For registered charities that would like to make changes to their charity during this time, including changes to their charities name, address, directors or charitable purposes, the CRA’s online CHAMP system is still available and it may be a good time to access the new system. You can read more about the CHAMP system in our article: CRA encouraging Canadian registered charities to file their annual T3010 using CHAMP online.

Note that charities with their T3010 due between March 18, 2020 and December 31, 2020 have an automatic extension until December 31, 2020 to file their T3010. See our article CRA Charities Directorate announces extension of T3010 filing deadlines till December 31, 2020 in response to COVID-19 for more information.