How to Prove Primary Care Responsibility to the CRA for a Grandchild

The CRA Cares About Daily Reality, Not Legal Documents

When a grandparent or relative applies for the Canada Child Benefit, the CRA doesn't ask whether you have custody. They ask whether you're the one actually running the child's life — meals, appointments, school drop-offs, bedtime. Section 122.6 of the Income Tax Act defines primary responsibility through daily care and upbringing, not through legal status.

The challenge is proving it. The CRA accepts "third-party operational evidence" — documents from people and institutions outside your family who can confirm the child lives with you and that you manage their daily needs.

The Five Categories of Evidence the CRA Accepts

1. School records

A letter from the school principal or office administrator stating that the child is enrolled, that your address is listed as the child's home address, and that you are the primary contact. Emergency contact sheets where you're listed first also work. Report cards mailed to your address help too.

2. Medical records

Registration cards from the child's doctor, dentist, or specialist showing your name as the responsible adult and your address as the child's home. Appointment records work, especially if they show a pattern of you bringing the child in over time.

3. Daycare or childcare records

Enrollment forms, payment receipts, or a letter from the daycare provider confirming that you registered the child and handle pickup and drop-off.

4. Community and social worker letters

If a social worker, band council member, community health nurse, or kinship support worker is involved with your family, a letter from them confirming the child's living arrangement is strong evidence. This is particularly relevant for Indigenous families working with First Nations Child and Family Services.

5. Activity registrations

Sports league sign-ups, library cards, community centre memberships, or religious organization records showing the child registered at your address under your care.

What Makes Evidence Strong vs. Weak

The CRA weighs evidence that comes from institutions and professionals — people with no stake in the outcome. A letter from the school carries more weight than a letter from a family friend.

The strongest evidence includes specific details: the child's full name, your name as the caregiver, your home address, and the date the relationship started. "To whom it may concern, [child's name] has been registered at our school since [date] and resides with [your name] at [your address]" is exactly what the CRA wants to see.

Avoid vague letters. "I believe [grandparent] takes care of the child" from a neighbour doesn't carry the same administrative weight as a school enrollment record.

When the CRA Requests Proof

The CRA typically asks for evidence in three situations:

• During initial application — especially when Part 5 of Form RC66 shows a change from one caregiver to another
• During a Validation and Controls review — periodic audits where the CRA verifies that benefits are going to the right person
• When two people claim the same child — if the biological parent is still listed as the CCB recipient, the CRA flags the overlap and asks both parties for proof

You can submit proof with your Form RC66 application before the CRA asks for it. This gives the CRA relevant evidence to review if it requests proof of primary care; submitting it upfront does not guarantee faster processing.

Building Your Proof Package Before You Need It

Start collecting evidence as soon as the child moves in:

1. Update the child's school enrollment to show your address and list yourself as primary contact
2. Register the child with your family doctor or the nearest walk-in clinic under your address
3. Keep copies of any communication from the school, medical office, or social services that shows your name and address
4. If you have a social worker or kinship support worker, ask for a letter confirming the placement
5. Save receipts for the child's clothing, food, school supplies, and activities — not because the CRA routinely asks for them, but because they establish a timeline if your application is audited

What If the Biological Parent Disputes Your Claim?

When both you and the parent claim the same child, the CRA sends validation notices to both of you asking for proof of where the child lives. If the parent can't provide evidence of ongoing residence — or doesn't respond within 30 days — the CRA transfers the benefit to you.

The parent's tax debt from any overpaid benefits is their problem, not yours. The CRA never reduces your CCB to recover money owed by someone else.

Our complete kinship guide includes fillable template letters you can hand to school administrators and doctors, a CRA communication log for tracking submissions, and a step-by-step evidence checklist tailored to grandparents and relative caregivers.

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