UPDATE: This is an update to our original
bulletin "CECRA is Dead, Long Live CERS." CERS is
currently in effect by virtue of the passing Bill C-9 into law on
November 19, 2020. Bill C-9 was enacted without amendment to its
original draft. However, Finance Minister Freeland has publicly
stated that the Federal Government will introduce
legislation to amend the contents of Bill C-9 so as to clarify that
qualifying rent expenses will also include "rent payable"
and not just "rent paid." Further, based on the
Minister's statement, the CERS application website confirms
that qualifying rent expenses must be "paid or payable"
and clarifies that if the applicant has not paid the amounts due
for its qualifying rent expenses yet, the applicant must attest
(confirm) that these amounts will be paid within 60 days of the
applicant receiving its rent subsidy payment.
