Electronic signatures – Extension of temporary measures T183 / T183CORP / T183TRUST
Today, CRA accounced that the 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; and
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.
You may have noticed that Forms T183/T183TRUST include a date and timestamp (Year/Month/Day and HH/MM/SS). The CRA will accept a date and timestamp that has been automatically populated by the software or manually entered by the taxpayer or electronic filer in instances where an electronic signature has been applied to the form. This will enable the CRA to track the number of instances that these forms are electronically signed for monitoring purposes. This will also support internal tracking and reporting on electronic signature use as the CRA continues to evaluate options for the application of electronic signature more broadly.
Due to the variety of electronic signature solutions available, with each having their own default settings for displaying date and time, electronic filers may need to adjust the document formatting settings within their electronic signature service account to ensure that the date and time are displayed on the electronically signed T183. Such adjustments to document formatting settings may be needed whether or not the electronic signature solution is integrated into the software or if it operates independently.
Third Party Electronic Signature Services – Certificate of Completion
In addition to the electronically signed T183 forms, third party electronic signature services may also provide a certificate of completion for the electronic signature. Electronic filers should also retain this document together with the electronically signed T183 forms should the CRA request them as part of our monitoring program. Retaining these certificates of completion will be especially important in the event that the electronically signed copy of the T183 forms do not display the timestamp of the electronic signature.
Masking of Social Insurance Number (SIN)
No matter the option used to obtain an electronic signature on the T183, electronic filers must ensure that the method used respects the safety and security of personal and tax information. To that end, the CRA has recommended to software developers that when Form T183 is printed or generated from tax software, that the first 5 digits of the SIN be masked. You will notice that the CRA also follows this practice when generating or displaying notices and statements that contain a SIN.