What Bill C-15 changes for your SR&ED claim (2026)

If your last SR&ED claim was filed under the old $3 million limit, the rules you remember are not the rules that apply to it any more — and that may include a year you have already filed. On March 26, 2026, Bill C-15 received royal assent¹ (Parliament of Canada; Department of Finance), and with it came the biggest expansion the SR&ED program has seen in over a decade. No legislative footnotes here — just what's different, and why you'd care.

1. The enhanced-credit limit doubled — $3M to $6M

The annual expenditure limit for the 35% enhanced refundable credit rose from $3 million to $6 million. For a Canadian-controlled private corporation claiming at the full enhanced rate, that doubles the maximum enhanced credit from about $1.05 million to $2.1 million a year². The full amount is refundable where the spending is current in nature — salaries, materials, contractors. Credits earned on capital expenditures are refundable at 40%, so the mix matters⁹ (Parliament of Canada — Bill C-15, SR&ED amendments; Income Tax Act s.127.1(2.01)).

In plain terms: there's now a much larger band of R&D spending that can earn the richest version of the credit before you hit the reduced rate. If your development spending had grown to where you were bumping against the old ceiling, there's a lot more headroom now.

These changes apply to taxation years that begin on or after December 16, 2024 — not from royal assent.⁸ For a December year-end company, that means your 2025 tax year is already under the new rules. If you filed that year under the old $3 million limit, an amended claim may be worth running.

2. Capital expenditures are eligible again

For the first time since the 2014 rules took them out, capital expenditures are SR&ED-eligible again — for property acquired or leased on or after December 16, 2024³ (Parliament of Canada — Bill C-15; CRA — SR&ED news and updates).

This is the one I'd flag hardest for businesses whose R&D lives in equipment rather than in software — food processors, manufacturers, anyone running a pilot line or buying instrumentation to test something that wasn't guaranteed to work. If you've bought or leased equipment to do genuine development work since that date, that spend may now be in scope where it wasn't a year ago. Worth pulling those purchase records before your next filing.

3. Growing companies stay in the enhanced band longer

The phase-out of the enhanced credit used to start squeezing you at $10 million of prior-year taxable capital and cut you off entirely at $50 million. Bill C-15 lifts that band to $15 million–$75 million⁴ (Parliament of Canada — Bill C-15; Income Tax Act s.127).

If your company has been scaling, this matters: you keep access to the enhanced refundable credit further up the growth curve than you would have before. There is also a new enhanced-credit class for public companies — see below.

A new door for public companies

The enhanced credit is no longer CCPC-only. A new class — Eligible Canadian Public Corporations — can now reach the 35% rate on up to $6 million of qualifying spend, which wasn't possible under the old rules.⁵ The phase-out works differently here: for a public corporation the $6 million limit is reduced on three-year average annual revenue between $15 million and $75 million, not on taxable capital. Broadly, an ECPC has to be resident in Canada, listed on a designated stock exchange, and not controlled by non-residents.

4. Pre-claim approval is live — find out before you spend

Since April 1, 2026, there's an optional pre-claim approval path: you can get an official determination from the CRA on whether your planned work qualifies before you start it or spend a dollar on it, rather than documenting a year of work and hoping⁶ (CRA).

The mechanics, straight from the CRA:⁷

• Who: a CCPC, Canadian corporation, or Canadian partnership, with annual gross income under $25 million, in good standing with the CRA.
• How fast: a determination within 8 weeks of completing the application in My Business Account.
• Scope: up to 3 projects per request, and the approval is valid for up to 3 years.
• Bonus: for approved projects that later need an expenditure review, processing drops from 180 days to 90.

For a first-time claimant, this takes most of the fear out of the process. You get an answer first, then proceed with confidence.

Why this is worth a second look

None of these changes require you to be a different kind of company than you already are. They widen the door for businesses that were already doing qualifying work — and, with capital eligibility, they reopen a whole category of spending that had been closed since 2014.

If your last claim predates the reforms, the most useful thing you can do is pull two short lists: any capital purchases or leases tied to development work since December 16, 2024, and the projects where the outcome was genuinely uncertain when you started. That's usually enough to tell whether the new rules change your number.

Sources

1. Bill C-15 received royal assent on March 26, 2026 (Budget Implementation Act, 2025, No. 1) — Parliament of Canada — Bill C-15 (45-1), Royal Assent; Department of Finance Canada — "Legislation passes to implement Budget 2025: Canada Strong" (Mar 26, 2026)
2. The 35% enhanced-credit annual expenditure limit rose from $3M to $6M (≈$1.05M → ≈$2.1M max refundable credit) — Parliament of Canada — Bill C-15, amended s.127(10.2) expenditure-limit formula ($6 million × [($60 million − A) ÷ $60 million]); Income Tax Act s.127(10.2), consolidated; Finance Canada — "Reforming and Enhancing the SR&ED Tax Incentive Program" (Dec 13, 2024)
3. SR&ED capital expenditures are eligible again for property acquired or leased on/after December 16, 2024 — Parliament of Canada — Bill C-15 ("restoring the eligibility of SR&ED capital expenditures"; applies to property acquired/lease costs incurred on or after December 16, 2024); PwC Canada — Tax Insights: Bill C-15
4. The taxable-capital phase-out band for the enhanced credit moved from $10M–$50M to $15M–$75M — Parliament of Canada — Bill C-15 (enhanced-credit threshold $15 million; phase-out formula reaching $75 million); Finance Canada — states the former $10M–$50M band and the move to $15M/$75M (Dec 13, 2024)
5. New enhanced-credit class for Eligible Canadian Public Corporations (35% rate on up to $6M of qualifying spend) — Parliament of Canada — Bill C-15 ("extending the enhanced credit to eligible Canadian public corporations"; defines "eligible Canadian public corporation"); Income Tax Act s.127(10.6) — the three-year average revenue phase-out
6. An optional SR&ED pre-claim approval path is live as of April 1, 2026 — CRA — "Innovate with confidence: CRA's SR&ED Tax Incentive Program launches a new Pre-claim approval process"
7. Pre-claim mechanics: CCPC/Canadian corp/partnership with annual gross income under $25M, in good standing; determination within 8 weeks; up to 3 projects; valid up to 3 years; expenditure-review processing cut from 180 to 90 days — CRA — Pre-claim approval process (tax tip, Apr 8, 2026); CRA — How to apply for pre-claim approval (Form T1322)
8. The changes apply for taxation years beginning on or after December 16, 2024 — not from royal assent — CRA — SR&ED news and updates; Finance Canada (Dec 13, 2024)
9. Credits on current expenditures are 100% refundable at the enhanced rate; credits on capital expenditures are 40% refundable — Income Tax Act s.127.1(2.01); CRA — SR&ED Investment Tax Credit Policy

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Want a second set of eyes on it? Book a 30-minute call with Amin — no prep, no obligation, and you talk to an engineer, not a junior. You can also read the full breakdown on the 2025 Reforms page.