On March 26, 2026, Bill C-15 received Royal Assent — and with it came the most significant overhaul of the SR&ED program in over a decade. As someone who spent years reviewing SR&ED claims from the inside at CRA, I want to cut through the noise and explain exactly what changed, what it means for Canadian businesses, and what you should do right now.
What Changed Under Bill C-15
1. The Expenditure Limit Is Doubled
The enhanced SR&ED expenditure limit for Canadian-controlled private corporations (CCPCs) has doubled from $3 million to $6 million. This means the maximum refundable federal tax credit has jumped from approximately $1.05 million to $2.1 million per year. The 35% refundable rate — the most valuable tier — now applies to twice as much eligible spending. If you were previously hitting the $3M ceiling, this change alone could significantly increase your annual refund.
2. Capital Equipment Is Eligible Again
This is a major reversal. Since 2014, capital expenditures — equipment, machinery, testing apparatus — were excluded from SR&ED claims. Bill C-15 restores their eligibility for property acquired after December 15, 2024. For companies in manufacturing, hardware development, AI/ML (think GPU clusters and compute infrastructure), and clean technology, this opens up substantial new claim value that has been off the table for over a decade.
3. Expanded Access for Mid-Sized Companies
The taxable capital thresholds that determine access to the enhanced 35% rate have been significantly raised. The lower threshold increases from $10 million to $15 million, and the upper threshold rises from $50 million to $75 million. This means more mid-sized companies that were previously phased out or partially phased out now have full or greater access to the refundable credit.
4. Public Corporations Now Qualify for the Refundable Credit
For the first time, eligible Canadian public corporations (ECPCs) — those listed on designated Canadian stock exchanges and controlled by Canadian residents — can access the 35% refundable SR&ED credit. Previously this was limited to CCPCs. If you have recently gone public or are planning to, this is a significant change worth discussing with your SR&ED consultant.
5. New CRA Pre-Claim Approval Process
Effective April 1, 2026, businesses can now apply to CRA for advance confirmation that a project qualifies for SR&ED before incurring costs or filing. Determinations are typically issued within eight weeks. This is especially valuable for large, multi-year R&D projects where you want certainty before committing significant resources.
What You Should Do Right Now
If your fiscal year started on or after December 16, 2024, these changes apply to you. Here is what I recommend: First, review any capital equipment purchased after December 15, 2024 — it may now be claimable. Second, if you were previously hitting the $3M expenditure ceiling, recalculate your potential claim under the new $6M limit. Third, if your taxable capital was causing a phase-out of your enhanced credit, reassess your eligibility under the new thresholds. Fourth, consider the Pre-Claim Approval Process for any major new R&D initiative.
A Note From Someone Who Has Reviewed These Claims
Having experience in reviewing SR&ED claims at CRA, I can tell you that the businesses that benefit most from these changes are the ones who act quickly and document everything contemporaneously. CRA’s scrutiny does not decrease when the program becomes more generous — if anything, larger claims attract closer review. Strong, contemporaneous documentation is more important than ever.