How to Access My Business Account and Authorize a Representative with the CRA

“My Business Account” is your organization's account page with the CRA. If your organization has a Business Number, it will automatically have a Business account. However, it can sometimes be difficult for organizations (charities especially) to register for or get access to My Business Account.

For businesses that have owners, the owner's SIN is automatically linked to the BN, which simplifies the process. Charities, of course, do not have owners -- but CRA considers the board of directors to be the "owner." This creates complexity for charities because as board members change, the owners list in My Business Account must be updated. If the list falls out of date, charities can have difficulties getting access.

When your Business Number is first set up, the owner of your organization will have their SIN automatically linked to your BN, and will be able to access My Business Account. For charities, the owner of the organization is typically the board of directors. If the board changes and new board members aren’t added to the owners list in My Business Account, it can lead to difficulties getting access.

Having access to My Business Account is very important, as it allows you, your accountant, or your bookkeeper to perform essential tasks related to GST/HST, payroll, and the administration of your charitable status.

We’ve seen a number of organizations run into roadblocks when adding a representative to My Business Account, so we’ve created the following instructions to help you along the way.

We’ve also addressed a number of common issues at the bottom of this page.

Adding a Representative

Before you start, you will need the following:

1. Your organization’s Business Number

2. The RepID, GroupID, or Business Number of the person or entity you’re adding as a representative

3. Make sure you can log into My Business Account as an owner, or to Represent a Client as a level 3 delegated authority (see: What is a “Level 3 delegated authority?” below for more information)

If you don’t have all of the above, see the bottom of this article for tips on how to get the process started.

Step 1: Log in through My Business Account using your regular CRA credentials

• Use whichever login information you use for your own CRA login. If you do not have a CRA login, follow the instructions through CRA sign-in services. 

• Note: Only business owners can authorize a representative through My Business Account. However, representatives with Level 3 delegated authority can also add new representatives through Represent a Client. 

  • If you have Level 3 access, log in to Represent A Client and enter your organization’s Business Number to access the Business Account. Start at step 2 below to complete the process of adding a representative.

Step 2: Go to “Profile” at the top of the page:

Step 3: Find “Manage authorized representatives” partway down the page:

Step 4: Click the “Authorize a representative” button

Step 5: Enter the RepID, GroupID, or Business Number (BN) of the entity you wish to authorize

• If you are a Young Associates client, you can use our Business Number: 818854564

Step 6: Click Next

Step 7: Select “Update and view (level 2)”. This allows your accountant or bookkeeper to view your information and submit filings on your behalf. For more information about the different levels of access, visit the CRA website.

Step 8: No expiry date is required

Step 9: Select “All accounts”

Step 10: Click Next

Step 11: Confirm and submit

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Common Issues, Questions, and Next Steps

• If you do not have a CRA login

  If you're not already registered with the CRA, follow the instructions through CRA sign-in services.

  If you already use your CRA “My Account”, you can use the same credentials to log into My Business Account and to Represent a Client.

• If have a CRA Login but have not signed in through My Business Account before

  If you're already registered for “My Account” with the CRA, you will also have access to My Business Account and Represent a Client. Use the CRA user ID and password (or sign-in partner) that you use for your personal CRA account to sign in to My Business Account or to Represent a Client.

• If you are able to log in to My Business Account but don’t see the BN of your organization or are seeing an error message

  Log in to My Business Account and navigate to “Manage profile – add BN to profile”.

  Enter your organization’s Business Number (BN).

  If your SIN or ITN is associated with the BN in the CRA’s records, you will now have access to My Business Account.

  If you encounter an error message with ref. code: MBA-001 when entering your organization’s Business Number in My Business Account, it means that your SIN is not associated with the BN in the CRA’s records.

  You will need to call the CRA at 1-800-959-5525 to request for your SIN to be associated with the BN. They will ask you to confirm your identity by responding to confidentiality questions that will require you to refer to recently filed tax documents and articles of incorporation. Have your files handy.

• If an owner at your organization already has access to My Business Account, and you also need access

  You can gain access as a level 3 delegated authority. Ask whoever currently has access to authorize you as a level 3 representative using your RepID.

  If you are an owner, partner, or director of the organization, you will want to be added to the CRA account as an owner. You will need to go through the process of adding yourself as an owner by following the instructions on this page of the CRA.

• If you do not have a RepID

  Visit the Represent a Client page and log in using your CRA login credentials. Once logged in, you will be prompted to set up a Represent a Client account and will receive a RepID.

  If you don’t have CRA login credentials, go to the Represent a Client page, scroll down to the link that says "CRA Register" and follow the instructions to log in.

• What is a “Level 3 delegated authority?”

  When an owner adds a representative to My Business Account, they can specify 3 levels of access (more information on this page of the CRA website). Level 1 is view-only. Level 2 can make certain changes to the account (this is the typical access you would grant your bookkeeper and accountant). Level 3 allows full access, including authorizing new representatives.

  Level 3 access can only be granted to an individual with a RepID, not an organization, and would typically be used to give access to Executive Directors or other high-level staff at an organization.

  If a delegated authority leaves their position, they should authorize another representative to fill their role. This ensures that owners or directors do not need to approve a new delegated authority.

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This tip sheet was created by the Young Associates team based on the best information available as of the date of posting.

The contents of this tip sheet comprise Young Associates’ views. They do not constitute legal or other professional advice. You should consult your professional advisor for advice relevant to your situation.

Founded in 1993, Young Associates provides bookkeeping and financial management services in the charitable sector, with a focus on arts and culture. Young Associates also provides consulting services in the areas of data management, business planning and strategic planning. Heather Young published Finance for the Arts in Canada (2005, 2023), a textbook and self-study guide on accounting and financial management for not-for-profit arts organizations.

Charities Working with Intermediaries

Registered charities are held to high standards of behaviour. Through the T3010 and its compliance program (read: audits) the CRA’s Charities Directorate monitors how charities receive and spend money. As a charity manager, you need to be careful about how you work with non-charities. Of course charities work with nonprofits and other organizations all the time! It is your responsibility to ensure that your working arrangements are compliant.

The CRA recently issued a new guidance document concerning charities working with non-charities in Canada, and we wanted to draw your attention to this new version of the plain-language guide to help you clarify your internal policies. Specifically, the issue is charities accepting money for the purpose of passing it on to another organization. In these cases, charities are accepting money on behalf of non-charities — often in situations where the non-charity solicits the funds — and are transferring the funds to the non-charity to use in various projects. 

Sometimes people refer to this as a “charitable trusteeship” (not language that CRA uses), and an avenue whereby a charity can help a non-charity to attract donations. Be careful! If this is how you’re thinking about it, quite likely you are not complying with the regulations.

According to the CRA, the Income Tax Act allows a charity to operate in only two ways:

1. carrying on its own charitable activities

2. making gifts to qualified donees

Qualified donees include registered charities and other organizations that have been granted status by CRA.

The worst-case scenario is an arrangement whereby the charity acts as a conduit by simply passing on the funds with no meaningful oversight.  CRA states, “a conduit is a charity that funnels its resources to a non-qualified donee without direction or control. Acting as a conduit contravenes the Income Tax Act, and could jeopardize a charity's registration.”

The key to remaining compliant is a written agreement — an “intermediary agreement” — drafted specifically with reference to CRA’s guidelines. 

The intermediary arrangement brings the relationship under point 1, above, making clear that it’s part of the charity’s own activities, and that the activity falls within the charity’s mandate. The agreement must specify how the charity will exercise direction and control over the project. This includes monitoring and supervising the activity throughout the duration of the project.

In order to comply with the Income Tax Act, you need to state, first, that your organization is a registered charity, set out how the proposed activities further your organization’s charitable objects, and then how you will monitor and supervise the project as it unfolds.

When these criteria are met, it is possible to remain compliant when entering into the agreement. Failure to comply with the CRA guidelines can result in temporary or permanent revocation of your charitable status, and we want to make sure that that doesn’t happen. 

Part of our service to you is to be conversant with applicable CRA rules, and alert to possible non-compliance risks. If you have any further questions, we are happy to assist in your research and share resources that may help in your decision-making. 

How Young Associates can assist

A consultation with us may make all the difference to your comfort level and confidence that your accounting system is up to the challenge of the pandemic. 

We’d also be happy to give you a quote for full-service bookkeeping. 

We work on the basis of fixed price agreements, so you’ll know going in how much our work will cost — and we always offer a money-back guarantee: if you’re not completely delighted with our service, we will, at your option, either refund the price, or accept a portion of said price that reflects your level of satisfaction. 

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This tip sheet was created by the Young Associates team based on the best information available to us as of the date of posting.

Although every effort has been made to provide complete and accurate information, Young Associates makes no warranties, express or implied, or representations as to the accuracy of content in this tip sheet. Young Associates assumes no liability or responsibility for any error or omissions in the information contained in the tip sheet. 

Founded in 1993, Young Associates provides bookkeeping and financial management services in the charitable sector, with a focus on arts and culture. Young Associates also provides consulting services in the areas of data management, business planning and strategic planning. Heather Young published Finance for the Arts in Canada (2005, 2020), a textbook and self-study guide on accounting and financial management for not-for-profit arts organizations.

By the end of 2018 charities will be able to manage CRA filings online

Staff Post
By Anna Mathew

By the end of 2018 charities will finally be able to do most of their government submissions and communications online. The improvements are part of the Charities Modernization Project (CHAMP) which came out of funds earmarked in the 2014 Federal Budget for IT improvements at the CRA. 

From the CRA:

The 2014 Federal Budget provided the Directorate with $23 million to modernize its IT systems over a five year period. Improving these systems will allow charities to apply for registration and file their annual returns electronically, reducing their administrative burden.

As part of CHAMP, by the end of 2018:

• Form T2050, Application to Register a Charity under the Income Tax Act, will be replaced by a new online application for registration e-service.
• Registered charities will be able to file their annual returns online through the CRA's My Business Account.
• The Charities Listings will be improved to help Canadians make informed choices about charitable giving.

Drache Aptowitzer has a September 2017 article which discusses the implications and how charities should prepare for the change to online submissions and communications. They advise:

1. Assigning a person inside the charity to be the main authorized user;
2. Ensuring that person is subscribed the the Charities Directorate e-lists and visits the Charities Directorate website regularly for updates;
3. Ensuring that person is aware of what information about charities is publicly available on the CRA website and understands the concept of 'garbage in garbage out' (if a charity gives bad quality data to the CRA, that bad quality data is what will be displayed in the publicly accessible CRA systems); and,
4. Ensuring that person is aware that all documents filed by the charity with the CRA will be available to all authorized users, so the charity should assess who currently has authorization and maintain their policy and update their authorization lists regularly.

Visit the full Drache Aptowitzer article here. 

At what point would our accumulated surplus be so large that we’d be in trouble with the Charities Directorate?

The Charities Directorate of the Canada Revenue Agency does, indeed, have rules around accumulation of property. The particular rule that charities are probably thinking about if they’re worried about the size of their accumulated surplus is the disbursement quota (DQ). The purpose of the DQ is to establish a minimum requirement for spending on charitable activities, with reference to the wealth that a charity has accumulated. As long as you maintain an appropriate level of charitable activity – measured through your spending – you are compliant with this rule.

CRA provides guidance about its spending requirements here. Note that there are separate rules for charitable organizations, which exist to deliver charitable programs and services, and foundations, which exist to support charitable programs and services.

Young Associates works with many smaller charitable organizations. Most groups in this category are unlikely to have accumulated property at a level that would cause non-compliance with the CRA. However, this is an issue that may involve complex legal and financial concepts. If you have concerns, it is wise to discuss your situation with a professional.

CRA defines its requirement for charitable organizations as follows:

If the average value of a registered charity's property not used directly in charitable activities or administration during the 24 months before the beginning of the fiscal period exceeds $100,000, the charity's disbursement quota is:

3.5% of the average value of that property.

The interpretation of this hinges on what property is not used directly in charitable activities or administration. CRA lists real estate and investments as examples. 

A charity, for instance, may hold long-term investments such as units in a mutual fund, and use the resulting interest revenue in its operations. However, the principal sits intact for multiple years, not directly used for charitable activity. (This is distinct from the case of a charity that places short-term investments to earn some interest revenue before the investment matures and the principal winds up in a chequing account, available for spending.)

A charity may also own a building that it doesn’t currently occupy; this may be the case for institutions such as hospitals, universities and churches, which may have considerable real estate holdings and needs that change over time.

Once you have identified property that meets CRA’s definition of “not used directly in charitable activities or administration,” you must calculate its average value over the two years before the start of the current fiscal year. CRA provides some latitude in how the average may be calculated. If your organization needs to make this calculation, the method for assessing value and calculating the average over time would be a good topic for discussion with your CPA.

Last step: calculate 3.5% of the average value. That yields the amount your organization is obliged to spend on its charitable activities or administration during the current year. 

Let's say your charity owns an investment portfolio, and you determined that its average value over the last 24 months was $100,000. Your DQ for the current year would therefore be $3,500.

You can see that this is actually a pretty low bar to jump over! Most organizations with the capacity to build a $100,000 investment portfolio would have operations that demanded more than $3,500 in program and admin spending. CRA’s rule is set at a level that catches inactive charities, but that is unlikely to cause compliance issues for most charities that are actively carrying out their mandates. 

UPDATED: Bureaucracy 101: Today, Class, We’ll File an RC59 Form!

Staff Post
By Heather Young

See update below on a new CRA form which allows changes to a charity’s director, trustee, or like official information .

Somehow, successfully completing an RC59 Business Consent form – which authorizes access to CRA accounts for HST, payroll and more – has often felt like a hit or miss process. Sometimes there’s no issue, and in other cases it has taken repeated attempts to get account contacts updated.

I had an illuminating conversation with a CRA officer that has helped to resolve some important misunderstandings, and I’d like to share what I’ve learned.

The RC59 form identifies two levels of authorization. Level 1 allows information-only access: that’s what your bookkeeper should have. Level 2 individuals are authorized to make changes to the account and the information it contains: that responsibility should belong to your organization’s senior staff. CRA lists the actions that can be performed by each level here.

One of the potential disconnects to understanding the process is that there’s actually a Level 3 which is not directly referenced on the RC59 form, although you’ll find its powers itemized on the preceding hyperlink. A Level 3 individual is also referred to as a Delegated Authority – a term that appears in the RC59 instructions section under the heading “Part 5 – Certification.” Only individuals authorized at Level 3 are allowed to sign (certify) RC59 forms. 

Note that, by virtue of their position, members of your board of directors automatically have Level 3 access to your CRA accounts. Your Executive Director or General Manager does not: they must be appointed by a Director. 

The RC59 instructions state, “This form must only be signed by an individual with proper authority for the business, for example, an owner, a partner of a partnership, a corporate director, a corporate officer, an officer of a non-profit organization, a trustee of an estate, or an individual with delegated authority.” 

The potential misinterpretation is to fail to recognize “delegated authority” as a legal term with a prescribed meaning. In the not-for-profit world, boards of directors commonly delegate a broad span of authority to their senior staff, who, for that matter, may have the term “officer” in their job title, as in Chief Executive Officer or Chief Financial Officer. The fact that you are responsible for CRA reporting, or that you sign T3010s or any other tax-related documents carries no weight, and the only officers CRA recognizes are the officers of your board of directors, such as the President, Treasurer or Secretary.

Individuals can be appointed to Level 3, Delegated Authority, upon proper completion of an RC321 form, Delegation of Authority. Since staff typically handle the nitty gritty of CRA interactions, it may be convenient for organizations to appoint their ED as a Delegated Authority, so that they have the ability to manage other account representatives. 

The whole system rests on CRA having access to a current list of directors and officers of the corporation. We’ve often been in the position of filing an RC59 after a long-serving staff member departs – and learning, after much bother, that the only other contacts on record with CRA are ancient history. 

And, here is another disconnect. Registered charities are accustomed to sending CRA a detailed board list annually as part of their T3010 Charities Return. All corporations (commercial and not-for-profit) must also file annual information returns to the appropriate jurisdiction (provincial or federal), naming their directors so that they can be added to the public record. However, CRA’s Business Number (BN) Services Unit does not employ these sources of information. 

You need to make a special request to CRA to update your board list for the purpose of BN administration. There is no official form for this task. According to the CRA officer I spoke to, you must write a letter requesting the update, listing your board members, and providing proof of their appointment; for instance, a copy of the AGM minutes including the motion electing the board. A search of the CRA website for confirmation of these verbal instructions yielded this link, which affirms the general intent, but does not specify the process. If you need to update your board list with CRA, perhaps a phone call to the Business Window (1-800-959-5525) would be the best place to start.

Note that CRA can ask board members to provide their Social Insurance Number. The Charities Directorate does not collect this information, but the CRA at large requires it because board members bear a personal liability for amounts held in trust for the Receiver General, such as unpaid payroll source deductions and HST remittances. 

With your board list up to date, you will always be able to update the RC59 as needed. Putting this on your AGM “to do” list sounds like a good addition to administrative best practices.

So, class, what are today’s main take-aways?

Well, I hope that this information helps to put RC59 woes behind us – but, really, the most important lesson to be learned is the significance of board members to what we usually classify as an administrative process. I suspect most ED’s would prefer that their board members stay out of the minutiae of CRA dealings – but in fact the law assigns Directors an essential role.

By virtue of their position, they have full access to the corporation’s dealings with CRA, and they are the gatekeepers to staff, who are typically charged with direct responsibility for tax filings, remittances and related matters.

And let’s not forget the financial liability issue. When someone joins your board, they assume personal responsibility – legally, up to the point of being held accountable for payment! – for ensuring that taxes are collected, reported and remitted according to the law.

The issues around processing RC59s serve as a good reminder of board members’ fiduciary responsibilities, the details of which may become lost or blurred in the day to day reality of their role as informed, engaged and active volunteers, supporting the paid professionals who carry out administrative operations.

Update:

Some feedback from one of our clients: 

Both Young Associates and [redacted] now have Level 1 authorization to quote "interact with the Canada Revenue Agency." 

I should give a big thank you for all parties involved, with a special shout-out to Heather for giving us very detailed instructions, and for her written column on the RC59, and for [redacted]'s assistance is helping us submit the forms 7x, or so.

I know more now than I ever wanted to do about this process.

update 2: 

As of December 2016, the CRA has created a form to change or update a charity’s director, trustee, or like official information. The form can be submitted by email, fax, or snail mail. Visit the CRA website for more information. 

Note from the CRA: 
This form does not replace the requirement to complete Form T1235, Directors/Trustees and Like Officials Worksheet, when you file your Form T3010, Registered Charity Information Return. Form T1235 is used to update the director, trustee, and like official information in the Charities Listings.

New CRA Guidance on Arts Activities and Charitable Registration

Staff Post
By Jerry Smith

A recent post by Andrew Valentine with the Miller Thomson Law Firm shone some light on a new piece of guidance from the Canada Revenue Agency. If you are currently considering an application for – or already possess – charitable status, the CRA has recently delivered the final version of the Guidance for Arts Activities and Charitable Registration (Reference CG – 018, December 14, 2012).

Building on feedback from the sector, including organizations such as CAPACOA seeking a broader definition of who could qualify, this finalized version attempts to clarify what CRA finds as acceptable examples of appropriate purposes to merit charitable status.

First, there are three broad categories of arts-related activities that could qualify as charitable purposes under one or more of the four heads of charity, including:

• Advancement of education;
• Exhibitions, performances and presentations of artistic works;
• Activities that enhance an art form or style within the arts for the benefit of the public.

In particular, CRA has clarified and expanded details in its arts forms and styles appendix, thus opening the door for more presenter members of CAPACOA to garner or maintain standing as a charity.

If you are interested in exploring these ideas in more detail, these links will be of value:

• Arts Activities and Charitable Registration – CRA Guidance
• CAPACOA Provides Input on Charitable Registration for Presenters