First tax season under new CRA disclosure rules offers second chance to Canadians

The overhauled Voluntary Disclosures Program provides a fresh path for taxpayers to correct past errors and avoid heavy penalties.

Jach Hoggen
4 Min Read
Canadian Revenue Agency signage is shown in Ottawa on Friday, June 28, 2024. THE CANADIAN PRESS/Sean Kilpatrick
Highlights
  • The 2026 tax season is the first full cycle under the updated Voluntary Disclosures Program (VDP).
  • A new two-tier system categorizes applications as 'unprompted' or 'prompted' for penalty relief.
  • Taxpayers can now qualify for relief even after receiving some CRA communications, provided no formal audit has begun.
  • Mandatory disclosure rules from Bill C-47 continue to require reporting for specific high-risk corporate transactions.

The 2026 filing season is the first full cycle under the Canada Revenue Agency’s rewritten Voluntary Disclosures Program. The new rules let people and businesses correct an old mistake without the full penalty, and in many cases without prosecution, if they come forward before an audit. The application is shorter than the old one. How hard the underlying rules still are is a separate issue, set out in CRA administration and tax complexity.

Unprompted and prompted disclosures

The old General and Limited streams are gone. The agency now splits applications into unprompted and prompted. An unprompted disclosure is one filed before the CRA has moved to identify the problem. That path can wipe 100 percent of the penalties and 75 percent of the interest. A prompted disclosure, filed after the agency has been in touch or has flagged the file, can still wipe the penalties, but interest relief drops to 25 percent. The split is meant to reward people who correct the return on their own. The data limits that make a fully automatic return unrealistic are described in the limits of automatic tax filing.

Who can still apply

A routine letter from the CRA no longer knocks someone out. Relief can still be available after general correspondence, as long as no audit or investigation has started. The form is the updated RC199. It is shorter, which matters because the old paperwork itself kept some people from correcting a return. The ordinary filing steps, for people who are not correcting an old year, are in how to file taxes in Canada.

What large companies still must report

The voluntary program does not replace mandatory reporting. Since Bill C-47 in June 2023, corporations have had to report notifiable transactions and reportable uncertain tax treatments. Those filings are due whether or not the company later uses the Voluntary Disclosures Program. Using the program to delay that mandatory report can make the company ineligible for relief.

Steps before an audit starts

  • Check past returns for income left off or claims that were too high.
  • Ask a tax adviser whether the case is still unprompted.
  • Complete form RC199 and describe the error in full.
  • Have the supporting papers ready.
  • File before the CRA opens an audit. The date decides how much interest can be waived.

What the agency is watching

The program only works if people know it exists. Many still assume an old error means a penalty or a charge. Through the 2026 season the CRA will see whether the shorter form and the clearer split actually bring more corrections in. For a first return, start with the filing checklist rather than with a disclosure.

Frequently Asked Questions

What is the difference between an unprompted and a prompted disclosure?

An unprompted disclosure is filed before the CRA contacts you or opens an audit. It can bring 100 percent penalty relief and 75 percent interest relief. A prompted disclosure, filed after contact, can still bring 100 percent penalty relief, but interest relief is 25 percent.

Can I apply if I already received a letter?

Yes, if the letter is general correspondence and the CRA has not started an audit or an investigation.

Do these rules cover large corporations?

They can use the program, but they still have to file the mandatory reports for notifiable transactions and uncertain tax treatments under Bill C-47. A voluntary disclosure does not replace those reports.

Share This Article