Du contrôle à la reddition de comptes : la réforme de 2022 sur les dépenses admissibles

In June 2022, the passage of Bill C-19 introduced what Canadian charity law now calls qualifying disbursements. In practical terms, it created a new pathway for registered charities to fund organisations that are not registered charities — grassroots groups, for example, or partners abroad — provided the funds are applied to charitable activities and properly documented.

Technical reforms rarely make headlines. This one deserves more attention than it received, because it touches the very heart of what our organisation exists to do: build bridges between institutions and the smaller groups doing essential work on the ground.

A shift in emphasis

Before the reform, charities working through non-charity partners had to demonstrate a high degree of ongoing direction and control over the partner’s activities. The new framework places greater emphasis on accountability: documenting the purpose of a grant, confirming that it is used exclusively for charitable activities, and reporting disbursements above a set threshold.

I welcome the spirit of that change. Relationships built on documentation and trust are, in my experience, healthier than relationships built on control. They allow community groups to retain their own voice and methods while still meeting their funders’ obligations.

Documentation as a partnership skill

The reform also makes clear that good record-keeping is no longer a back-office concern. It is a condition of partnership. Both funders and grantees benefit from simple, shared practices:

• A written grant agreement stating purpose, activities and reporting expectations.
• Clear budgets and receipts, retained in an organised and secure manner.
• Brief narrative reports describing what was done and what changed.
• Named contacts on each side who understand the obligations.

None of this requires sophisticated systems. It requires consistency.

Why it matters for small groups

For many grassroots organisations, the barrier to receiving charitable funding has never been the quality of their work; it has been their legal form. Reforms that lower that barrier, while preserving accountability, widen the circle of people who can be supported. That is a development every bridge-builder should welcome — and prepare for.

This reflection is general in nature and is not legal advice.