Fixing past tax mistakes: the CRA's Voluntary Disclosures Program

If you’ve left income off a return, claimed something you shouldn’t have, or never filed at all, the CRA’s Voluntary Disclosures Program (VDP) lets you come forward and fix it. You still pay all the tax you owe, but if the CRA grants relief, it cancels penalties and part of the interest, and won’t refer you for criminal prosecution over what you disclosed.

The program changed on October 1, 2025. This guide describes the rules for applications the CRA receives on or after that date, set out in Information Circular IC00-1R7 (and GST/HST Memorandum 16-5-1 for the GST/HST and other taxes). Applications received before October 1, 2025 are reviewed under the older rules, in IC00-1R6.

Who it’s for

Most taxpayers can apply, including individuals, employers, corporations, partnerships, trusts and GST/HST registrants. Situations that may be eligible include:

• you didn’t file a return for a past year, and it’s now at least a year late
• you didn’t report, or under-reported, income, including foreign income that’s taxable in Canada
• you claimed expenses you weren’t entitled to
• you didn’t remit employees’ source deductions, such as CPP contributions or EI premiums
• you didn’t file information returns, such as Form T1135 for foreign property
• you didn’t charge, collect or report GST/HST, or claimed GST/HST credits, refunds or rebates you weren’t entitled to

You’ll typically not be eligible if the disclosure would give you a refund or leave no tax or penalties owing, if you’re seeking relief from penalties or interest that have already been assessed, if you’re asking to make or change an election, or if there’s an insolvency event for the years involved.

The five conditions

To get relief, your application has to meet all five:

1. It’s voluntary. You apply before an audit or investigation has started into you, or a related taxpayer, about what you’re disclosing. That includes audits and investigations by other authorities, such as law enforcement or a securities commission, not only the CRA.
2. It’s complete. You include all the relevant information and documents for the years required.
3. There’s something to relieve. The error or omission carries interest, penalties or both.
4. It’s at least a year old. The information is at least one year, or one reporting period, past its filing due date.
5. You pay, or arrange to. You include payment of the estimated tax owing, or ask for a payment arrangement, which the CRA has to approve.

Because of the fourth condition, the VDP isn’t available for a return that’s less than a year (or one reporting period) past its filing due date. Our guides to changing your return and missing the deadline cover the usual routes.

The CRA also says it continues to restrict eligibility for people who are under audit or investigation and those who were egregiously non-compliant.

The relief: general or partial

Since October 1, 2025, relief depends on whether your application is unprompted or prompted.

• Unprompted means there was no communication about the specific issue before you applied, or the only contact was an education letter or notice offering general guidance on a topic. Unprompted applications normally get general relief: relief of 75% of the applicable interest and 100% of the applicable penalties.
• Prompted means you applied after the CRA (or another authority) told you about a specific error or omission on your account, or set a deadline for you to fix it, or after the CRA already had information from third parties about your possible non-compliance. Prompted applications normally get partial relief: relief of 25% of the applicable interest and up to 100% of the applicable penalties.

Either way, if your application qualifies, you won’t be referred for criminal prosecution and gross negligence penalties won’t apply to what you disclose. For the GST/HST, certain “wash transactions” can get full relief of penalties and interest.

Relief is limited by law to a 10-year period: penalties for tax years that ended in the 10 calendar years before the year you apply, and interest that built up during those 10 calendar years.

How to apply

1. Gather the documents. Include every return, form, statement and schedule needed to correct the problem: the last ten years if it involves foreign income or assets, the last six years for Canadian income or assets, and the last four years for GST/HST. You can leave out years in those periods that have no errors.
2. Disclose everything you know. You must disclose all known errors and omissions, and name anyone, such as a tax professional or promoter, who helped or advised you on what you’re disclosing.
3. Fill in Form RC199, Voluntary Disclosures Program (VDP) Application, and sign it. If a representative applies for you, you both sign, and the representative must be authorized with the CRA.
4. Send it one way only: online through My Account, My Business Account or Represent a Client, or by fax or mail to the VDP in Shawinigan, Quebec. The addresses are on the CRA’s how-to-apply page.

The CRA sends an acknowledgement letter confirming your effective date of disclosure, and relief, if granted, applies up to that date. If the CRA asks for more information during its review and you don’t provide it in time, it can deny the application as incomplete.

Not sure yet? Ask first

You can ask for a pre-disclosure discussion before you reveal who you are. It’s informal, anonymous and non-binding: it can help you understand the process, the relief and the risks of staying non-compliant, but it doesn’t guarantee relief and doesn’t stop the CRA from auditing you. Request one with the CRA’s online callback request form.

After the decision

The CRA sends a letter saying whether your application was prompted or unprompted, which level of relief you got and for which years, or why relief was refused. The CRA can still audit or verify anything you disclosed.

There’s no right to file an objection to a VDP decision. If you think the CRA wasn’t fair or reasonable, ask in writing for a second administrative review, then, if needed, apply to the Federal Court for a judicial review within 30 days of the decision being sent to you.

How it differs from taxpayer relief

The CRA’s taxpayer relief provisions are for when events beyond your control, such as a serious illness, an accident or a disaster, kept you from meeting your tax obligations. The CRA may also grant relief when you can’t pay because of financial hardship, or when the charges resulted from its own actions, such as errors or delays. You explain your circumstances and ask the CRA to cancel or waive penalties and interest. Assessed tax doesn’t qualify, and the same 10-year limit applies. The CRA says its current average processing time for these requests is about 16 months.

The VDP is for coming forward to correct errors or omissions in your filings. If you don’t qualify for the VDP, you may be eligible for taxpayer relief instead, and you can ask for relief of penalties and interest the VDP didn’t cancel, if your situation fits the taxpayer relief rules.

In short

• Apply before the CRA contacts you about a specific issue to get the most relief.
• Send a complete, signed Form RC199 with the corrected returns and your payment or a payment arrangement request.
• If you owe a balance you can’t pay at once, our guide to owing the CRA covers payment arrangements.