The XRB is proposing to increase the tier 2 and 3 public benefit entity (PBE) size thresholds as follows:

• Tier 2: total expenses ≤ $33 million (currently $30 million); and
• Tier 3: total expenses ≤ $5 million (currently $2 million).

We support in principle the proposal to increase the tier 2 and tier 3 PBE size thresholds as it is a step in the right direction to address many of our members’ concerns around regulatory burden, especially on smaller charities and not-for-profits. We agree that it is important that the benefits of reporting do not exceed the costs, especially for smaller tier 2 PBEs.

We agree with the proposal to increase the tier 2 PBE size threshold to account for inflation. However, we would welcome a more detailed basis for the proposed increase to the tier 3 PBE size threshold. The consultation document does not identify the criteria that was applied in arriving at the proposed increased tier 3 PBE size threshold. The analysis in the consultation document is also limited to the population of registered charities; it extrapolates this analysis to incorporated societies and excludes the public sector.