New Retention Requirements for Church Offering Envelopes

Authored by Philip Milley, Associate Director of Legal Affairs

The Canada Revenue Agency (CRA) recently published new guidelines regarding the retention period for church offering envelopes.[i] The primary change in the guidelines relates to the length of time churches are expected to retain offering envelopes. The old CRA guidelines required a church to retain offering envelopes for a period of two years following the end of fiscal period for which they were issued, unless the donations are recorded from the envelopes directly into a ledger.

The new guidelines require churches to retain offering envelopes for a period of six years following the end of the last taxation year to which the envelope relates. CRA takes the position that an envelope may be the only source document that may provide proof that a cash donation was made and support the amounts recorded in a ledger. This requirement applies to the 2015 taxation year and onward. The statement of the new position is as follows:

Church offering envelopes are NOT duplicate receipts but documents that enable the Minister to verify donations made for which a deduction or tax credit is available under the Act. Where an envelope is used as a source document, which is generally the case with cash donations, offering envelopes are to be kept for a period of six years from the end of the last taxation year to which the envelope relates in accordance with s. 230(2) and s. 230(4) of the Income Tax Act.  

CRA will continue to allow the electronic retention of offering envelopes so long as the electronic copy is an intelligible reproduction in an ‘electronically readable’ format.[ii]  For more information and guidance regarding compliance with books and records best practices refer to CCCC’s Record Retention Periods Checklist.

[i] http://www.cra-arc.gc.ca/chrts-gvng/chrts/prtng/bks-eng.html

[ii] See CRA Information Circular IC78-10R5: Books and Records Retention/Destruction (June, 2010) http://www.cra-arc.gc.ca/E/pub/tp/ic78-10r5/ic78-10r5-10e.html