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22 October 2025

Ban On Large Cash Donations Not Included In Bill C-12, But Still Included In Bill C-2

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Miller Thomson LLP

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On October 8, 2025, the government introduced Bill C-12, the Strengthening Canada's Immigration System and Borders Act, which intends to accelerate several of the less controversial measures from the Original Bill.
Canada Corporate/Commercial Law
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In our recent article, Proposed new federal rules may ban large cash donations: What charities and non-profits need to know, we noted that the Government of Canada had proposed a broad prohibition on cash transactions over $10,000 (including donations) through Bill C-2, An Act respecting certain measures relating to the security of Canada's border and the integrity of the Canadian immigration system, which was originally introduced in June (the "Original Bill").

On October 8, 2025, the government introduced Bill C-12, the Strengthening Canada's Immigration System and Borders Act, which intends to accelerate several of the less controversial measures from the Original Bill. This decision was made after the government faced pushback from civil liberties organizations and other concerned groups – including the Charities and Not-for-Profit Section of the Canadian Bar Association – regarding several measures in the Original Bill.

We understand that Bill C-2 will still proceed through Parliament; however, the measures now addressed in Bill C-12 will be removed from the existing Bill C-2. Notably, the proposed ban on large cash transactions is not included in Bill C-12, but whether it gets passed with the rest of Bill C-2 remains to be seen. In its news release, Public Safety Canada stated: "Bill C-12 was introduced to enable Parliament to pass these priorities to protect Canadians while permitting additional time to evaluate the other measures announced in June 2025."

This is a developing story, and we encourage readers to check our Insights regularly or subscribe to the Social Impact Newsletter for further updates.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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