Key takeaway: Bill C-15 received royal assent on March 26, 2026, and rewrote the size of the SR&ED program without touching how you file. The expenditure limit for the enhanced 35% refundable credit doubled from $3 million to $6 million, worth up to $2.1 million a year instead of $1.05 million. Eligible Canadian public corporations can now earn that enhanced rate for the first time. Capital expenditures are claimable again. None of it changed the 18-month filing deadline, the forms, or the provincial grind — only the number at the end got bigger.
Bill C-15 rewrote the SR&ED program's dollar limits, and most of what changed works in your favour: bigger limits, a wider phase-out band, a new class of eligible company, and capital spending back on the table. A company still planning against the old $3 million ceiling is leaving money on the table it doesn't have to.
Here's every number that moved, who's newly eligible, and, just as important, the parts of the program that Bill C-15 left completely alone.
Everything the SR&ED changes 2026 brought, in one place
Budget 2025 became law as Bill C-15 when it received royal assent on March 26, 2026, and it rewrote four things in the SR&ED program: the expenditure limit, the phase-out range, who counts as eligible for the enhanced refundable rate, and whether capital expenditures qualify at all. Every one of these changes applies to tax years beginning after December 15, 2024, per the CRA's investment tax credit policy.
None of it is retroactive relief for older years, and none of it touches the mechanics of filing. It's purely a change to how much money is available and who can reach it. If your fiscal year began before December 16, 2024, you're still working under the old limits for that year.
The basic ITC rate stays at 15% for everyone, refundable at 40% for qualifying corporations and individuals. The enhanced 35% refundable rate is the one that moved, and it moved in four specific ways below.
How the $6 million expenditure limit changed your ceiling
The expenditure limit for the enhanced 35% refundable credit doubled, from $3 million to $6 million of qualifying spend per year, for tax years beginning after December 15, 2024. At the full $6 million limit, that's up to $2.1 million in refundable credits annually, compared to a maximum of $1.05 million under the old $3 million ceiling.
That number matters because the 35% rate on current expenditures is 100% refundable up to the limit: cash back even if your company owes no tax. A CCPC spending $4 million a year on eligible R&D used to hit the old $3 million ceiling and get the leftover $1 million taxed at the lower 15% rate. Under the new limit, that entire $4 million earns the 35% rate. For companies scaling past the old ceiling, this is the single largest change in the bill.
Capital expenditure ITCs at the 35% rate are 40% refundable rather than 100%, and qualifying corporations get 40% of their 15%-rate credit refunded. It's the same refundability structure as before, just applied to a bigger base.
Put in concrete terms: a CCPC with $6 million in eligible current expenditures used to see $3 million taxed at 35% and $3 million taxed at the basic 15% rate. Under the new limit, the full $6 million qualifies for 35%. That difference is the entire point of this change. It doesn't require a bigger R&D team or a bigger raise. It requires the same spend, recalculated against the number that changed underneath it.
The phase-out band moved too, so you keep the rate longer
The taxable-capital phase-out range for the enhanced rate widened from $10 million–$50 million to $15 million–$75 million, per the CRA's investment tax credit policy. Eligible Canadian public corporations (ECPCs) instead use a 3-year average gross revenue test over that same $15 million–$75 million band, and CCPCs may elect to use the revenue method too.
Practically, this means a growing CCPC keeps its full enhanced rate for longer before the phase-out starts eroding it. A company that would have started losing the 35% rate at $10 million in taxable capital under the old rules now has until $15 million. That's real runway for a startup whose balance sheet is filling up with a recent raise, not R&D success.
Who newly qualifies for the enhanced rate
Eligible Canadian public corporations can now earn the enhanced 35% refundable credit for the first time, something that was flatly unavailable to any public company before this bill. The eligibility bar, per the CRA: listed on a designated stock exchange, resident in Canada, and not controlled by non-residents.
This is a narrower door than it sounds; most public companies don't meet all three conditions simultaneously. But for the ones that do, it's a change from zero access to the enhanced rate to full access, using the same $15 million–$75 million revenue-based phase-out described above. If you're a Canadian-listed company that assumed SR&ED's best rate was CCPC-only, that assumption is now out of date.
Capital expenditures are eligible again
Eligible capital property acquired after December 15, 2024 can be claimed for SR&ED again, per the CRA's program updates page. Capital expenditures had been excluded from the program for years; this bill reopens that door specifically for property acquired after the mid-December 2024 cutoff, not earlier purchases.
The refundability rule is different for capital than for current expenditures: the 35%-rate credit on capital expenditures is 40% refundable, not 100%. If your R&D involves purpose-built lab equipment, specialized test rigs, or hardware bought specifically for an eligible project, this is worth revisiting even if you wrote capital spending off as ineligible in past years.
The new pre-claim approval process didn't exist a year ago
As of April 1, 2026, the CRA runs an optional pre-claim approval process that tells you whether a project qualifies before you've spent the money on it. You apply through My Business Account, and the CRA issues a determination, including a meeting, within 8 weeks.
It's open to CCPCs, other Canadian corporations, and partnerships with gross business income under $25 million, in good standing, for projects that haven't previously been claimed and aren't in litigation. You can submit up to 3 projects, an approval holds for up to 3 years, and a claim built entirely from pre-approved projects gets routed to an accelerated 90-day expenditure-only review instead of a full technical review. We covered the mechanics in more depth in our pre-claim approval guide. It's a genuinely new tool, not a rebrand of the pre-claim consultation service, which still exists separately.
What the 2026 changes did not touch
The 18-month filing deadline is exactly what it was before Bill C-15. A corporation's SR&ED reporting deadline is still 12 months after its T2 filing due date, which is 18 months after fiscal year end, and the CRA still cannot legally extend it under subsection 220(2.2) of the Income Tax Act. We wrote the full mechanics of that rule here; nothing in this bill changes a word of it. The only thing the new limits change about the deadline is the size of what you lose by missing it.
The provincial "grind" is also untouched. Provincial and territorial R&D credits still reduce the pool of qualified SR&ED expenditures used to calculate your federal credit, under ITA subsection 127(18). Combined federal-plus-provincial rates were never additive, and they still aren't. If you're stacking an Ontario, BC, Quebec, or Alberta credit against the federal rate, the grind rule applies exactly as it did before this bill, just against a bigger federal base.
The claim itself is still built the same way: Form T661 plus Schedule T2SCH31 (or T2038(IND) for individuals), with the CRA's technical eligibility test unchanged: advancement of knowledge, uncertainty, systematic investigation. The CRA has released an updated "(26)" version of T661 and companion forms to reflect the new limits, plus a new SR&ED Client Portal inside My Business Account, but the underlying eligibility test, what actually qualifies as SR&ED, is identical to last year's. We go through that form line by line in our T661 guide.
Processing times also didn't move by legislation, though the government committed to cutting SR&ED processing time in half as part of the same announcement. The CRA's existing service standards, 60 calendar days for refundable claims accepted as filed and 180 days for those selected for review, were already being met at 95% and 92.5% respectively in FY2025-26. The commitment is about pushing an already-functioning standard further, not fixing a broken one.
The program is bigger, and the data shows it
The scale of the SR&ED program backs up how much room the new limits create. In FY2025-26, per the CRA's annual program statistics, the CRA processed 23,677 claims and allowed $4.6 billion in investment tax credits, up from $4.5 billion the year before on 22,738 claims processed. 90% of claims were accepted as filed with no modification, 6% were adjusted, and 4% were denied. 59% of ITCs allowed were refundable, and software development alone accounted for 42.6% of ITCs allowed.
None of that is a comment on your odds; approval rates are a function of documentation, not the size of the limit. But it tells you the program isn't shrinking to absorb the bigger limits — it's the same CRA infrastructure processing the same proportion of claims cleanly, now against a larger dollar ceiling per company.
What this means if you're filing under the new rules now
If your fiscal year began after December 15, 2024, you're filing under the new numbers whether you've updated your internal SR&ED math or not. Run your actual eligible spend against the new $6 million limit before you assume your claim is capped where it used to be — a company that stopped counting eligible expenditures once it hit the old $3 million ceiling has been leaving the enhanced rate on the table for anything beyond that point.
The same goes for capital spending you previously wrote off as ineligible, and for public companies that assumed the enhanced rate was closed to them entirely. Both assumptions predate this bill.
This is also where continuous documentation earns its keep, because a bigger limit only helps if your evidence supports a bigger claim. A claim that stalled out at the old $3 million ceiling for two or three years running probably has documentation habits built around that smaller number — fewer projects tracked, less granular time allocation, narratives written for a claim half the new size. Scaling the claim to match the new limit means scaling the evidence first.
Glauq's approach is to capture the technical narrative continuously from the tools your team already uses, Jira, GitHub, Slack, instead of reconstructing it at filing time, so a claim that's grown into the new $6 million ceiling has the paper trail to back it, and a qualified independent SR&ED expert reviews and stands behind every claim before it's filed. Automation handles the collection; the expert takes responsibility for what goes in front of the CRA.
Whatever route you take to file, the practical move this year is the same: recalculate against the actual 2026 numbers, don't assume last year's ceiling still applies, and treat the deadline as the one thing in this program that a bigger budget didn't soften. For the full picture of the current program, see our 2026 SR&ED guide.
Frequently asked questions
What is the SR&ED expenditure limit for 2026? The enhanced 35% refundable credit now applies to up to $6 million of qualifying expenditures per year, for tax years beginning after December 15, 2024 — double the previous $3 million limit, per the CRA's investment tax credit policy. At the full limit, that's up to $2.1 million in refundable credits in a single year.
When did the SR&ED changes take effect? Bill C-15 received royal assent on March 26, 2026, but the SR&ED provisions apply to tax years beginning after December 15, 2024 — so many companies were already operating under the new rules before the bill formally passed. Check your fiscal year start date against that cutoff before assuming which rules apply to you.
Did the SR&ED filing deadline change in 2026? No. The 18-month-after-year-end deadline for corporations is unchanged, and the CRA still cannot legally extend it under subsection 220(2.2) of the Income Tax Act. Only the dollar value behind a missed deadline changed — it roughly doubled.
Can public companies now claim the enhanced SR&ED rate? Yes, for the first time. Eligible Canadian public corporations — listed on a designated stock exchange, resident in Canada, and not controlled by non-residents — can now earn the enhanced 35% refundable credit, using a 3-year average gross revenue test for the phase-out instead of taxable capital.
Are capital expenditures eligible for SR&ED again? Yes, for eligible capital property acquired after December 15, 2024, per the CRA's program updates page. The 35%-rate credit on capital expenditures is 40% refundable, versus 100% refundable for current expenditures.
Does the provincial grind still apply after these changes? Yes. Provincial and territorial R&D credits still reduce your federal qualified expenditure pool under ITA subsection 127(18), and combined rates are still not additive. The grind rule works exactly as it did before Bill C-15, just against the new, larger federal base.
The math changed; the deadline and the eligibility test didn't. Run your 2026 numbers against the real limits before you assume last year's ceiling still holds.
See what your claim could be worth under the new limits — estimate your refund or check your eligibility.