CRA Voluntary Disclosures Program: 2025 Rules Checklist

Kanewealth Advisory Inc. Published 9 September 2026 Last reviewed against CRA guidance 9 September 2026 Reading time ~12 minutes

Governing policy: IC00-1R7 (income tax)
Memorandum 16-5-1 (GST/HST & excise)
Applies to: Applications received on or after 1 Oct 2025
Best case relief: 100% penalties · 75% interest · no prosecution
Relief window: 10 calendar years before the year you apply
Never relieved: The underlying tax itself

What changed on 1 October 2025

IC00-1R7 supersedes IC00-1R6 · Memorandum 16-5-1 supersedes 16-5

The old two-track General Program / Limited Program structure has been retired. It is replaced by a test of how the taxpayer came forward rather than how badly they behaved. In practice this widens the door: contact from the CRA that stops short of an audit no longer disqualifies you — it costs you 50 percentage points of interest relief.

Old regime compared with the current regime
Element	Before 1 Oct 2025 (IC00-1R6 / 16-5)	On or after 1 Oct 2025 (IC00-1R7 / 16-5-1)
Track names	General Program / Limited Program	Unprompted / Prompted application
Test applied	Nature of the taxpayer's conduct — was it intentional, egregious, a large corporation?	Whether the CRA had already communicated about an identified compliance issue
Top-track interest relief	50%	75%
Lower-track relief	Limited Program: gross negligence penalty not applied, other penalties still assessed, 0% interest relief	Prompted: up to 100% penalty relief and 25% interest relief
Effect of an education letter	Could route the file to the Limited Program or defeat voluntariness altogether	Still eligible, classified as prompted Eligibility widened
Large corporations	Corporations with gross revenue over $250M in 2 of the last 5 years were routed to the Limited Program	No revenue-based routing rule is restated in IC00-1R7 Confirm before relying
Completeness standard	"All relevant information", open-ended in practice	Fixed minimum document windows of 6 / 10 / 4 years
Application form	Prior version of Form RC199	Simplified Form RC199, dated 1 October 2025
Pre-filing contact	Anonymous pre-disclosure discussion by telephone	Telephone plus a dedicated online callback request form

The date that matters is the date the CRA receives your application, not the tax years being disclosed. An application received on 30 September 2025 is still decided under the old rules.

Types of application

IC00-1R7 ¶19–20 · Memorandum 16-5-1 ¶17–19

Three classifications, one of them GST/HST only
Type	Trigger test	Typical situation	Relief level
Unprompted	No verbal or written communication from the CRA about an identified compliance issue	You or your accountant find an unfiled T1135, unreported rental or crypto income, or unremitted source deductions — with nothing in the CRA mailbox	General relief
Prompted	Application follows verbal or written CRA communication about an identified compliance issue, but before an audit or investigation has begun	An education letter about unreported income or ineligible expenses; a formal demand or notice to file a specific return	Partial relief
Wash transaction	GST/HST only — tax was not charged on a supply to a registrant who would have been fully entitled to recover it	A registrant failed to charge GST/HST to a fully ITC-entitled recipient, so there was no net revenue loss to the Crown	Full relief

The distinction that decides the money

A generic automated overdue-return reminder is generally not treated as destroying voluntariness. A communication identifying a specific compliance issue makes your application prompted. An audit or investigation already opened on the matter makes it ineligible altogether. Those are three different states, and only the middle one is a discount rather than a disqualification.

Practitioner commentary also warns that a connection to a related person already under audit can jeopardise a voluntariness claim. Commentary, not CRA text

Relief levels and limits

IC00-1R7 ¶19–21 · Memorandum 16-5-1 ¶17–19 · Memorandum 16-3-1 for wash transactions

What is actually forgiven
Relief level	Applies to	Penalties	Interest	Criminal prosecution	Tax owing
General relief	Unprompted applications	100% relieved	75% relieved	No referral	Payable in full
Partial relief	Prompted applications	up to 100%	25% relieved	No referral	Payable in full
Wash transaction relief	Qualifying GST/HST wash transactions	100% relieved	100% relieved	No referral	Per Memorandum 16-3-1

Read "up to 100%" as discretionary

For prompted applications the CRA offers penalty relief of up to 100%. That is not the same as the flat 100% granted on unprompted files, and the CRA has not published the criteria it uses to grant less. Plan for the possibility that some penalties survive on a prompted application.

The second point to be clear about from the outset: the tax itself is never relieved. Neither is the remaining 25% or 75% of interest. The program removes the punitive layer, not the debt.

What the timing is worth — an illustration

Illustrative example — $60,000 of unreported income, $18,000 tax, $9,000 accrued interest, $4,500 of penalties
Outcome	Tax	Penalties	Interest	Total payable
No disclosure, later reassessed	$18,000	$4,500	$9,000	$31,500
Prompted application	$18,000	$0–4,500	$6,750	$24,750–29,250
Unprompted application	$18,000	$0	$2,250	$20,250

These figures are a constructed illustration to show the shape of the gap, not a CRA example and not a prediction for any particular file. The spread between the two application rows is the cost of waiting for the CRA letter to arrive.

The ten-year limitation period

Income Tax Act s. 220(3.1) and equivalents · IC00-1R7 ¶21

Relief is bounded by the same statutory limitation that governs taxpayer relief generally. The Minister may relieve penalties for tax years or reporting periods ending within the 10 calendar years before the calendar year in which the application is filed, and interest that accrued during the 10 calendar years preceding the year the request is made.

Older years do not disappear. They must still be disclosed, and the tax on them is still payable — they simply fall outside the relief the Minister is permitted to grant.

Relief window by year of application
Application filed in	Earliest tax year eligible for penalty relief	Interest relievable from
2025	2015	1 Jan 2015
2026	2016	1 Jan 2016
2027	2017	1 Jan 2017

A file that straddles the boundary is worth filing before 31 December. Waiting until January drops the oldest year out of the relief window permanently.

Three time limits that get confused with each other

Relief limitation10 years, statutory

How far back the Minister may forgive penalties and interest. Fixed by statute — the CRA cannot extend it.

year you applyminus 10 calendar years

Document window6 / 10 / 4 years

The minimum supporting documents that must accompany the application. A completeness standard, not a relief rule — and the CRA may ask for more.

most recent6 domestic · 10 foreign · 4 GST/HST

Disclosure dutyno ceiling

The full duration of the non-compliance must be explained even where it predates the document window. The CRA reserves the right to audit years outside the application.

however far back it runsunbounded

Confusing the second limit with the third is the most common way an application that looked complete turns out not to be. Sending six years of documents does not answer the question of when the non-compliance actually started.

Eligibility — the five conditions

IC00-1R7 ¶10 · Memorandum 16-5-1 ¶8

All five must be satisfied. Failing any one of them makes the application invalid, not merely reduced.

VoluntarySubmitted before an audit or investigation into the matter has been initiated. A generic overdue-return reminder does not defeat this; a letter identifying a specific issue makes the application prompted rather than ineligible.
CompleteAll relevant information for all required tax years or reporting periods is included. A known omitted year can invalidate the whole application.
Involves a penalty or interest exposureThere must be an error or omission that attracts applicable interest, penalties, or both. Corrections that only produce a refund do not qualify.
At least one year past dueIncome tax: the year is at least one year past its filing due date. GST/HST and excise: at least one reporting period past due.
Payment includedPayment of the estimated tax owing, or a request for a payment arrangement, must accompany the application.

Who can apply

Individuals, employers, corporations, partnerships and trusts; GST/HST registrants, excise duty and excise tax licensees, air carrier designates, softwood lumber exporters, and persons with remittance obligations.

Statutes the indirect-tax memorandum covers

Memorandum 16-5-1 reaches well beyond GST/HST
Statute	Typical disclosure
Excise Tax Act	GST/HST not collected or remitted, or over-claimed input tax credits
Excise Act, 2001	Duty on tobacco, cannabis, vaping products, spirits and wine
Underused Housing Tax Act	Unfiled UHT returns on residential property
Select Luxury Items Tax Act	Luxury tax on vehicles, aircraft and vessels
Greenhouse Gas Pollution Pricing Act	Fuel charge registrant obligations
Digital Services Tax Act	DST registration and returns
Global Minimum Tax Act	Pillar Two top-up tax filings
Air Travellers Security Charge Act	ATSC collection and remittance
Softwood Lumber Products Export Charge Act, 2006	Export charge reporting

What is not eligible

Refund or nil-balance applications — anything that would produce a refund, or where no tax or penalty is owing.
Penalties or interest already assessed — that belongs to the Taxpayer Relief Program, not the VDP.
Elections under any Act the CRA administers.
Insolvency — bankruptcy, receivership and similar proceedings.
Advance pricing arrangements — matters covered by an APA with the CRA.
Tax treaty discretion — matters that depend on the Minister exercising discretion under a treaty.
GST/HST credit-side adjustments — an increase in input tax credits, other credit adjustments or rebates without a corresponding increase in tax liability in the application period.

The VDP and Taxpayer Relief are sequential, not alternatives

The VDP operates before assessment; the Taxpayer Relief Program operates after. A file that arrives with penalties already assessed on the disclosed years is in the wrong queue. Where both are filed, the CRA treats them separately.

Supporting documents — how far back

IC00-1R7 ¶27–28 · Memorandum 16-5-1 ¶25

Minimum document windows by type of error
Nature of the error or omission	Documents required	What that means in practice
Assets or income located outside Canada	10 most recent years	Foreign account statements, Form T1135, foreign trust and corporation filings, foreign tax returns
Canadian-sourced income or assets	6 most recent years	T1 and T2 returns and schedules, financial statements, source-deduction records
GST/HST and other indirect tax	4 most recent years	Returns, working papers, sales and input tax credit listings for the affected reporting periods

Tax years or periods with no errors need not be included.
These are minimums. The CRA may request documents beyond the window, and reserves the right to audit years outside the application.
The full duration of the non-compliance must still be explained even where documents are not required for those years.
A mixed file — unreported foreign dividends and a GST/HST gap in the same corporation, say — carries both windows at once.

Callback request and pre-disclosure discussion

IC00-1R7 ¶13–15 · Memorandum 16-5-1 ¶11 · CRA tax tip, 15 June 2026

The CRA now offers a dedicated online callback request form alongside the telephone route. The conversation is free, anonymous, informal and non-binding — and it buys no protection whatsoever.

What the pre-disclosure discussion is, and what it is not
Attribute	Position
How to request it	The CRA's online VDP callback request form, or by telephone — individuals 1-800-959-8281, businesses 1-800-959-5525
Anonymous	Yes. Preliminary discussions can happen before your identity is revealed
Binding on the CRA	No. Explicitly informal and non-binding
A guarantee of relief	No. The discussion does not constitute a guarantee of relief under the VDP
Effect on the CRA's audit powers	None. It has no impact on the CRA's ability to audit or penalise a taxpayer
Sets the effective date of disclosure	No. Only a filed application does that
What it is genuinely useful for	Testing eligibility, understanding which relief level is likely, and understanding the risk of staying non-compliant

Do not treat the callback as holding your place

The date that matters is the effective date of disclosure, and that is assigned when the CRA receives and acknowledges your application — not when the pre-disclosure call happens. If the CRA opens an audit between the call and the filing, the opportunity is gone. Where the facts are already clear enough to file, file.

The simplified RC199 and how to file

Form RC199, version dated 1 October 2025

The CRA rebuilt Form RC199 to be simpler and easier to use. It is published as an accessible fillable PDF and a print version. The form on its own is not the application — it is the cover sheet on a package.

What the package must contain

Completed Form RC199The current version, dated 1 October 2025, signed by the taxpayer.
Every return, form and schedule needed to correct the non-complianceNot summaries — the actual filings, prepared as they should originally have been.
Supporting documentation for the applicable window6 years domestic, 10 years foreign, 4 years GST/HST. Years with no errors may be omitted.
A written explanation of the full duration and cause of the non-complianceIncluding periods older than the document window.
Payment of estimated tax owing, or a payment arrangement requestAn application without either is not a valid application.
Representative authorisation, where applicableBoth taxpayer and representative sign. The representative must already be on file with the CRA, or the authorisation must accompany the package.

Submission channels — use one only

Duplicate submissions across channels delay processing
Channel	Route	Notes
Online Preferred	"Submit documents" in My Account, My Business Account or Represent a Client	Fastest acknowledgement, and therefore the earliest effective date of disclosure
Fax	1-888-452-8994	Keep the transmission confirmation
Mail	Voluntary Disclosures Program 4695 Shawinigan-Sud Boulevard Shawinigan QC G9P 5H9	Slowest to acknowledge; use tracked delivery

Applications may be filed at any time of year. The only timing requirement is that the year or reporting period is at least one year past its due date.

After filing: review, decision and recourse

IC00-1R7 ¶33, ¶38–42

The sequence, and what each step can fix
Stage	What happens	Deadline or limit
Acknowledgement	The CRA acknowledges receipt and assigns an effective date of disclosure. If relief is granted it applies up to that date.	—
Information requests	A CRA officer may request further information or documents.	Within the timeframe the CRA gives; failure to respond can result in denial
Decision letter	States the application type, the relief level granted, and the eligible tax years or reporting periods. A denial states its reasons.	—
Objection	Not available. There is no right of objection to a VDP decision — it is discretionary.	Not applicable
Second administrative review	Written request for review by the Assistant Director, Shawinigan National Verification and Collections Centre.	No statutory deadline stated; do not delay
Judicial review	Federal Court, Form 301 Notice of Application, plus filing fees.	30 days from the date the CRA sent the notification

Second and subsequent applications

The CRA may consider a further application from the same taxpayer where the circumstances were beyond the taxpayer's control, or where the application relates to a different matter than the earlier one. It is discretionary and should not be planned for.

Common misunderstandings, and where the guidance is thin

Read this before relying on an expected outcome

Known failure modes and open questions
Issue	Why it matters	Status
Out-of-date guidance online	A large amount of material still describes the General Program / Limited Program. That framework was superseded for applications received on or after 1 October 2025.	Check the date on any source
"Up to 100%" penalty relief	The CRA has not published the criteria for granting less than full penalty relief on prompted applications.	No published criteria
Large-corporation treatment	The former $250M revenue routing rule has no restated equivalent in IC00-1R7. How large corporations are treated in practice is untested.	Unresolved
Related-party audits	An audit of a related person may compromise voluntariness on your own file.	Commentary, not CRA text
Treating the callback as protection	The pre-disclosure discussion is anonymous and non-binding, does not stop an audit, and does not set the effective date of disclosure.	Common misconception
Documents mistaken for disclosure scope	The 6 / 10 / 4-year windows are a minimum document standard, not the scope of what must be disclosed or what the CRA may audit.	Common misconception
Second-review timing	The CRA states no fixed deadline for requesting a second administrative review, but the 30-day Federal Court clock runs from the original notification.	Do not let the 30 days lapse
Egregious conduct	The CRA continues to say it restricts access where non-compliance is egregious, without defining the threshold in IC00-1R7.	Discretionary

Working out whether a disclosure is the right move?

The difference between an unprompted and a prompted application is measured in real money, and the ten-year relief window closes a year at a time. If you are weighing a voluntary disclosure — for unreported income, foreign assets, unfiled returns or a GST/HST gap — we can assess the file and prepare the application.

Speak to Kanewealth Advisory See our taxation services

Sources

All primary sources are Canada Revenue Agency publications

IC00-1R7 — Voluntary Disclosures ProgramCRA · primary
GST/HST Memorandum 16-5-1 — Voluntary Disclosures ProgramCRA · primary
Form RC199 — VDP ApplicationCRA · form
Voluntary Disclosures Program — program landing pageCRA
Changes to the VDPCRA
Who is eligibleCRA
How to applyCRA
Our review and decisionCRA
VDP callback request formCRA · tool
CRA tax tip — your second chance to set things right (15 June 2026)CRA · news
Archived Memorandum 16-5 — applications 1 Mar 2018 to 30 Sep 2025CRA · superseded

Important. This page is general information about a Canada Revenue Agency program. It is not tax, accounting or legal advice, it does not create a professional relationship, and it must not be relied on as a substitute for advice on your own circumstances. Eligibility for the Voluntary Disclosures Program and the relief granted are discretionary decisions of the CRA, and outcomes vary by file.

Items marked Confirm before relying or Commentary reflect areas where CRA guidance is unsettled or where the point comes from third-party commentary rather than published CRA text.

Content prepared from CRA guidance current at 9 September 2026. CRA policy changes; verify against Information Circular IC00-1R7 and GST/HST Memorandum 16-5-1 before acting. Kanewealth Advisory Inc. accepts no liability for action taken on the basis of this page alone.

The CRA Voluntary Disclosures Program