Entities Must Report Beneficial Ownership Discrepancies Effective October 1, 2025
Summary
Starting October 1, 2025, reporting entities regulated by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) must report material discrepancies between beneficial ownership information obtained and individuals with significant control (ISC) information in Corporations Canada's database. This obligation applies when the reporting entity determines that an active corporation incorporated under the Canada Business Corporations Act poses a high risk of a money laundering offence or terrorist activity financing offence. The requirement establishes a new compliance channel between FINTRAC-regulated entities and Corporations Canada for beneficial ownership data quality.
“Starting October 1, 2025, reporting entities regulated by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) are required to report to Corporations Canada any material discrepancies identified between the beneficial ownership information that they have obtained and the individuals with significant control (ISC) information available in Corporations Canada's database.”
Reporting entities subject to FINTRAC obligations should confirm whether their existing beneficial ownership data-collection workflows include a step to compare against Corporations Canada's ISC registry, and whether any active CBCA corporate clients have been assessed as high-risk for money laundering or terrorist financing — those are the trigger conditions for this reporting obligation. The scope is narrower than a universal reporting requirement; the obligation exists only when the reporting entity itself makes a high-risk determination.
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What changed
The notice establishes a new reporting obligation for FINTRAC-regulated entities to report material discrepancies between beneficial ownership information and ISC data to Corporations Canada, effective October 1, 2025. The obligation is triggered only when a reporting entity determines that a CBCA-incorporated corporation presents a high risk of money laundering or terrorist activity financing.
Affected FINTRAC-regulated entities that conduct beneficial ownership due diligence on CBCA corporations should review their discrepancy-identification procedures and establish reporting workflows to Corporations Canada. Entities should consult the Corporations Canada beneficial ownership discrepancy reporting guidance to understand the specific thresholds for material discrepancies and the reporting mechanism.
What to do next
- Consult the Beneficial ownership discrepancy reporting guidance for when and how to report a material discrepancy
Archived snapshot
Apr 25, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
Reporting entities required to report discrepancies in beneficial ownership information as of October 1, 2025
Starting October 1, 2025, reporting entities regulated by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) are required to report to Corporations Canada any material discrepancies identified between the beneficial ownership information that they have obtained and the individuals with significant control (ISC) information available in Corporations Canada's database. This is required when the reporting entity determines that an active corporation incorporated under the Canada Business Corporations Act (CBCA) poses a high risk of a money laundering offence or terrorist activity financing offence.
For guidance on discrepancy reporting obligations, including when and how to report a material discrepancy, reporting entities can consult Beneficial ownership discrepancy reporting.
Related information
- Search for a Federal Corporation
- Individuals with significant control
- Not publishing information about a corporation's individual with significant control
Date modified:
2025-10-01
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