What’s a RCAAA?: Registered Amateur Athletic Associations in Canada
- Lex Klombies
- Jun 30
- 3 min read
Registered amateur athletic associations (“RCAAA”s) are a kind of “qualified donee” under the Income Tax Act (Canada). You might think of them as quasi-charities. While they are not charities at law, RCAAAs and other qualified donees have similar powers and obligations as registered charities—including the ability to issue official donation receipts for tax purposes.
Think your organization might qualify as a RCAAA? This is a unique kind of entity, and you may benefit from specialized legal support. But to get you started, here are some of the eligibility criteria Canada Revenue Agency (“CRA") has published:
Criteria
To be registered as a Canadian amateur athletic association, the association that is applying must be created and resident in Canada and it must have the promotion of amateur athletics in Canada nation-wide as its exclusive purpose and exclusive function.
The following could be considered as advancing the exclusive purpose of the promotion of amateur athletics in Canada on a nation-wide basis:
regulate a sport and the way it is played
promote a sport
oversee a structure of local clubs, and regional, provincial, and territorial bodies involved in a sport
deliver a training program that brings promising athletes from the grassroots level to national and international levels through various qualifying competitions
manage a national team to participate at international competitions
stage and sanction local, regional, provincial, territorial, and national competitions
act as a Canadian representative of an international federation controlling a sport
provide a training and certification program for coaches and referees
carry out fundraising activities and redistribute funds for local, regional, provincial, and territorial member organizations
To be registered, the association must also devote all its resources to its exclusive purpose and function.
No part of the association's income can be payable to or available for the personal benefit of any proprietor, member, or shareholder of the association unless the proprietor, member, or shareholder was a club, society, or association whose primary purpose and function was promoting amateur athletics in Canada.
This is not an exhaustive list of all the ways an organization might promote amateur athletics and qualify as a RCAAA. The Federal Court of Appeal has explicitly stated that it is an error to "[treat this] list of acceptable purposes and functions as being the only acceptable purposes and functions for an organization to qualify as a [RCAAA]”. (Athletes 4 Athletes Foundation, 2021 FCA 145 at para 68 (a)).
It is particularly important to note that RCAAAs must function nation-wide, or they are ineligible to be RCAAAs. CRA’s own policy on the topic is:
Organizations that cannot be registered
Certain clubs and organizations, like those listed below, are not eligible for registration because they do not function on a nation-wide basis:
organizations of a local, regional, provincial, or territorial character
organizations whose primary purpose is to train and field a single team of athletes, regardless of the level of competitions
organizations that operate a local training or other facility that is not directed toward high-performance athletes, regardless of whether this facility is open to athletes from across Canada in theory or in practice
organizations that use sports as a means to achieve another more primary purpose
What does nation-wide mean? You may need legal advice to sort out whether your organization may be eligible.
Here’s an interesting tidbit. The Federal Court of Appeal determined that nation-wide does not mean “a physical presence in each province or territory” (Tomorrow’s Champions Foundation, 2021 FCA 146, at para 69]. While not immediately intuitive, it appears to be a reasonable interpretation — imagine the absurdity of requiring a RCAAA delivering a mountain climbing or sailing training program to Canadian amateur athletes to maintain some kind of physical presence in every
province and territory!
Looking for experienced legal support for founding or maintaining a Registered Amateur Athletic Association? Schedule an initial discussion with Lex Klombies: Book now.
Sources & Resources:
Athletes 4 Athletes Foundation, 2021 FCA 145
Tomorrow’s Champions Foundation, 2021 FCA 146
This is general information, not legal advice — and it may not reflect the current law. If you need support with changing your charitable purposes and activities, book a consult. Our team would be happy to help!
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