Electronic signatures – Extension of temporary measures T183 / T183CORP / T183TRUST

I’ve just received an email from the CRA where they stated the following:

"Electronic signature measures announced in Budget 2021 have not been enacted, and as a result, the CRA is extending its administrative measures for electronic signature on forms:

  • T183, Information Return for Electronic Filing of an Individual’s Income Tax and Benefit Return
  • T183CORP, Information Return for Corporations Filing Electronically
  • T183TRUST, Information Return for the electronic filing of a Trust Return
  • T2200, Declaration of Conditions of Employment
  • T2200S, Declaration of Conditions of Employment for Working at Home Due to COVID-19

In order for the CRA to accept the use of electronic signatures between third parties for these forms, it is expected that identity verification has been performed by the party receiving the signed form and the electronic signature that is incorporated in, attached to or associated with the form must satisfy the following conditions:

a) if the electronic signature is applied to the form in person by the individual, it is applied in the presence of the other party using methods such as a stylus or finger on a tablet; and
b) if the electronic signature is not applied to the form in person by the individual, it is either
i) applied to the form that is then sent to the other party using the electronic address most recently provided to the other party for that purpose; or
ii) applied to the form that is then sent to the other party through an access controlled, secured electronic location, such as a secure website, that is accessible to the individual only because the other party has made that location known and granted access to the individual.

The administrative measures for electronic signature do not extend to the discounting forms RC71, Statement of Discounting Transaction, and RC72, Notice of the Actual Amount of the Refund of Tax.

We encourage you to review the electronic signature options available for these forms. The CRA will continue to provide updates on a regular basis."

My question is, are we still allowed to accept electronic signatures on the authorization as representative request form and business consent authorization form? They didn’t mention anything about those forms however on the CRA website, however it still shows that they accept electronically signed authorization forms. Just wanted some clarifications on that.

Hi Guy,

Can you provide a reference? Where on the CRA website does it say:

?

I could not find it. Despite that, I will continue to accept electronically signed AuthRep forms for personal tax clients. Since CRA is allowing e-signed T183s without it being enacted in law, I suspect the same concept applies to ALL signed forms - we must ensure we have verified who is signing.

I no longer get business clients to sign AuthRep forms. It is a waste of time and effort, now that CRA has made it so that the client MUST approve the request through their “My Business” account online. It is just as easy to give the client instructions on how to AUTHORIZE my firm as it is to give the client instructions on how to APPROVE our signed and submitted authorization request. Yes, the client must type in my firm’s business number, but they don’t need to sign any kind of form, and thus we don’t need to print or send such a form, or worry about how to verify the identity of the signer.

On the other hand, CRA does not, will not, and cannot reasonably request an original “wet signature” version … and all they’re gonna get is a digitized (PDF) copy, scanned likely. They would be unable to determine categorically that there was no original wet signature on same.

It’s a nothingburger.

And some clients are simply unable to get a MyBA (they lack computing skills, access or are disabled in one or more of many ways, too elderly now to do so, but still maintain a business…

This is a stupid policy by CRA to require mandatory MyBA accounts and eventually this will backfire badly on them.

I managed to find this from CRA’s website:
Question: Does the CRA accept electronic signatures on Form T1013?
Answer: Yes. The CRA does accept electronic signatures on Form T1013.
https://www.canada.ca/en/revenue-agency/services/e-services/e-services-tax-preparers/information-tax-preparers-about-form-t1013-authorizing-cancelling-a-representative.html

Although they’ve stopped calling the T1013 form as authorization requests, they have not mentioned on their latest notification that we can still use e-signatures on personal authorization requests.

Now you’re giving them too much credit lol. I’ve been trying to get the CRA to accept the GST 20 election form for one of my clients so that we can change their frequency filing to annually. However it’s been more than 2 months since we sent the form by mail with no sort of acknowledgment from the CRA which has been quite frustrating and infuriating, all because a client forgot their login details and locked access to their CRA My Business account. If a business that is planning to use our MUST have their business account or else we won’t take their case!