CRA Response to the 2025 Systemic Examination Report: Timing is everything
Original report submitted to the Minister of National Revenue January 2025.
Recommendation 1
The Taxpayers’ Ombudsperson recommends that the CRA find an effective way to remind taxpayers whose immigration status on file with the CRA is about to expire that they must provide proof of any update to their legal status to ensure there is no benefit interruption.
CRA’s response
The CRA agrees with this recommendation in principle.
The CRA will explore different ways in which it can remind temporary residents that their benefit payments will cease if they do not prove that they continue to meet the citizenship requirements.
Improvements to be analyzed include:
- Adding a reminder to every annual Canada child benefit (CCB) notice.
- Adding the on-file expiry date to the notice and attempting to make this information more prominent.
This analysis and associated actions will be completed by May 2026.
2025 update
As of October 20, 2025, the CRA will begin including the following verse, with the on-file expiry date in bold, to CCB notices in an effort to make the information more prominent.
“According to our records, your [or your spouse or common-law partner’s] temporary resident permit will expire on [expiry date]. If the permit expires, you will not receive benefits unless you renew it.”
This action plan item has been completed.
Recommendation 2
The Taxpayers' Ombudsperson recommends that the CRA provide a way for taxpayers to verify the expiry date of their immigration status in the CRA’s system from their CRA account.
CRA’s response
The CRA agrees with this recommendation in principle.
The CRA will analyze the feasibility of adding the citizenship expiry date to CRA’s My Account. However, it should be noted that the information displayed will only be a reflection of what the client has provided to the CRA. A disclaimer will be included to ensure that it is clear to the client that Immigration, Refugees and Citizenship Canada is the primary source of this information.
As indicated in the CRA’s planned actions related to recommendation #1, the CRA will also explore adding the on-file expiry date to the annual CCB notice.
The analysis for this recommendation will be completed by May 2026.
2025 update
Preliminary analysis is currently underway to assess the feasibility of adding temporary resident status expiry dates to CRA’s MyAccount.
The analysis for this recommendation is on track to be completed by May 2026.
Recommendation 3
The Taxpayers' Ombudsperson recommends that the CRA review the initial notices it sends to temporary residents to determine whether it could make information that requires action more prominent.
CRA’s response
The CRA agrees with this recommendation.
The CRA will review different ways in which it can make information more prominent on notices sent to temporary residents.
As noted in the CRA’s planned actions related to recommendation #1, improvements to be analyzed include:
- Adding a reminder to every annual CCB notice.
- Adding the on-file expiry date to the notice and attempting to make this information more prominent.
This analysis and associated actions will be completed by May 2026.
2025 update
A verse will be added to every annual CCB notice as a reminder that temporary residents must send the CRA their permit extension information before their permit expires to avoid payment interruptions.
The CRA is on track to add the verse by May 2026.
Recommendation 4
The Taxpayers' Ombudsperson recommends that the CRA provide information online at the “Keep getting your payments” Webpage for temporary residents who are eligible for the CCB on what they need to do to prevent their payments from stopping, and what they can do to get their payments reinstated, if they are stopped.
CRA’s response
The CRA agrees with this recommendation.
The CRA will review the Keep getting your payments - Canada child benefit (CCB) webpage, to ensure complete information is provided to temporary residents.
This will include adding temporary resident-specific information on:
- how to maintain benefits as a temporary resident;
- how to send permit updates to the CRA via My Account or mail;
- how to reinstate benefits if they have been stopped;
- contacting IRCC should an error exist on their permit.
This action will be completed by October 2025.
2025 update
The Keep getting your payments - Canada child benefit webpage has been updated with the following information:
Temporary resident status
To maintain your eligibility and avoid payment interruptions:
- Send a copy of your renewed or extended permit to the CRA through Submit Documents in My Account or by mail to your tax centre.
- If your permit expired and you did not apply for a renewal or extension before the expiry date, your benefits will stop. You will need to contact IRCC to restore your status.
- If your new permit has not yet been issued, you must submit a copy of the letter or screenshot from IRCC’s online portal confirming that your extension or application is in progress.
- If your permit contains incorrect information, you can contact IRCC to request a correction. Once updated, send the new version to the CRA.
This action plan item has been completed.
Recommendation 5
The Taxpayers' Ombudsperson recommends that the CRA centralize the information it provides to newcomers and includes information targeted at temporary residents.
CRA’s response
The CRA agrees with this recommendation.
The CRA is developing a newcomer brochure webpage that centralizes information for newcomers to Canada. The enhanced webpage addresses the process and timelines for updating information, highlighting the importance and impact of keeping immigration status information up to date.
Updated content on our existing newcomer factsheets indicates that eligible individuals must hold a valid permit in their 19th month. Future updates will provide additional guidance for temporary residents on the requirements to continue receiving benefit and credit payments.
The updated newcomer webpage will be launched in early 2025 and updated fact sheets will be available in the summer of 2025.
2025 update
The CRA launched a new enhanced webpage for newcomers in March 2025. The updated content addresses key barriers that newcomers face when filing taxes for the first time as well as accessing benefit and credit payments. It provides guidance for newcomers of all immigration statuses, including temporary residents, on getting government payments and what needs to be done to continue receiving them.
A new infographic promoting benefit and credit payments launched in July 2025. The updated content highlights the importance of residency status in order to be eligible to receive payments. It also speaks to temporary residents who have lived in Canada for the previous 18 months and have a valid permit in the 19th month. The infographic advises temporary residents to inform the CRA if their permit is renewed to avoid interruptions to payments.
In addition to the infographic, a new factsheet for newcomers was launched in October 2025. The new factsheet will speak to the same information introduced in the new infographic in addition to promoting the Form RC66, Canada Child Benefits Application and Form RC66SCH, Status in Canada and Income Information for the Canada Child Benefits Application (for newcomers with children) and the Form RC151, GST/HST Credit and Canada Carbon Rebate Application for Individuals Who Become Residents of Canada (for newcomers with no children). These forms allow newcomers to apply for benefits and credits as soon as they arrive.
This action plan item has been completed.
Recommendation 6
The Taxpayers' Ombudsperson recommends that the CRA communicate directly and in a timely manner with temporary residents who are likely in their 19th month of continuous residency in Canada and who may have children under 18 years old about their potential eligibility for the Canada child benefit.
CRA’s response
The CRA does not agree with this recommendation.
The CRA cannot determine if a taxpayer is a temporary resident based on a tax return.
The only instance in which citizenship information is collected is upon application for the CCB, as this is the only CRA program in which citizenship information is required.
While residency information is collected on a tax return, it is just one element of the CCB eligibility criteria. The CRA has no way of knowing if the taxpayer has remained in Canada after the 18-month residency period has passed.
Further, the CRA cannot determine if a taxpayer resides with a child under 18 years of age or is primarily responsible for the care and upbringing of that child, based on a tax return. Claiming a child as a dependent on a tax return does not equate to being an eligible individual for the CCB.
Given the considerations above, the CRA will not pursue communicating directly with individuals who may be temporary residents and possibly eligible for CCB.
Recommendation 7
The Taxpayers' Ombudsperson recommends that the CRA allow taxpayers to track CCB correspondence through its progress tracker.
CRA’s response
The CRA agrees with this recommendation in principle.
Currently, the CRA does not have the capacity or resources to expand the Progress Tracker to include CCB correspondence items, but will revisit adding CCB correspondence to the progress tracker at a later date.
In the interim, the CRA will pursue recommendation #8 which will provide clarity to individuals on our processing timeframes.
2025 update
The interim measure of completing the action plan for recommendation #8 has been completed, and CCB correspondence has been added to the drop down menu on the Check CRA processing times web page to show taxpayers our current timeline to process.
Preliminary analysis is underway to assess the feasibility of expanding the Progress Tracker to include CCB correspondence items. At present, developmental capacity for the secure portals is limited due to other high-priority initiatives. Discussions are ongoing to confirm timing and feasibility of this enhancement.
The analysis for this recommendation is on track to be completed by May 2026.
Recommendation 8
The Taxpayers' Ombudsperson recommends that the CRA should be as transparent as possible and inform taxpayers through its CRA’s Check Processing Time tool of how long it will take to process CCB correspondence.
CRA’s response
The CRA agrees with this recommendation.
The CRA will add information to the Check CRA processing times web page about how long it takes to process CCB correspondence.
This action plan will be completed by October 2025.
2025 update
CCB correspondence has been added to the drop down menu on the Check CRA processing times web page to show taxpayers our current timeline to process.
This action plan item has been completed.
Recommendation 9
The Taxpayers' Ombudsperson recommends the CRA improve how it processes immigration status updates for CCB recipients when there is a gap period and the new permit does not reflect that their status was maintained.
The CRA should explain to taxpayers why they will not get payments for the gap period and who they should contact if they had maintained status for the whole period.
CRA’s response
The CRA does not agree with this recommendation.
The CRA cannot adjust its process in anticipation of potential gaps in information an applicant has from another department. It remains the client’s responsibility to prove that they have maintained their citizenship status during a gap period.
However, as agreed to in recommendation #4, the CRA will review the Keep getting your payments - Canada child benefit (CCB) webpage, to ensure complete information is provided to temporary residents.
This will include adding temporary resident-specific information on:
- how to maintain benefits as a temporary resident;
- how to send permit updates to the CRA via My Account or mail;
- how to reinstate benefits if they have been stopped;
- contacting IRCC should an error exist on their permit.
Information will also be provided to Contact Centre agents so that they can better assist temporary residents with issues regarding maintained status, gap periods and their impact on CCB eligibility.
Recommendation 10
The Taxpayers' Ombudsperson recommends that the CRA review the length of time it considers someone to be a newcomer after their arrival in Canada.
CRA’s response
The CRA does not agree with this recommendation.
As per section 114 of the ITA, an individual who is resident in Canada throughout part of the year and non-resident throughout another part of the year is assessed differently on the income tax and benefit return than a full-year resident. Accordingly, the CRA considers an individual to be a newcomer for the first year they are a resident of Canada. However this term is not related to the eligibility criteria for benefits.
In order to help individuals file their tax returns correctly, information is posted on the CRA website targeting newcomers (part-year residents who arrive to Canada) and emigrants (part-year residents who leave Canada). If the CRA were to change the length of time it considers someone to be a newcomer, this would impact the definitions of “newcomers” and “emigrants”, which are terms CRA uses to help people identify the concept of a part-year resident. Part-year residents of Canada can claim federal non-refundable tax credits based on the number of days they were a resident of Canada.
A benefits outreach strategy was developed and implemented to ensure newcomers understand Canada’s tax system, have the information and support they need to file their tax returns, and are able to access the benefits and credits they are entitled to. This strategy acknowledges newcomers may be Canadian residents beyond twelve months.
Recommendation 11
The Taxpayers’ Ombudsperson recommends that the CRA implement an information sharing agreement with IRCC to get immigration information and that it continue collaborating with IRCC to work towards an automated solution to get real-time data by March 2026. This would allow the CRA to have access to timely information, which would improve service to temporary residents.
CRA’s response
The CRA agrees with this recommendation in principle.
The CRA will be establishing an information exchange agreement with IRCC to improve the administration of the CCB. However the CRA has no authority to impose this action or a timeline on IRCC.
2025 update
The CRA and IRCC are collaborating to develop an information sharing agreement to support the CRA in determining CCB eligibility for temporary residents.
While the CRA has no authority to impose a timeline on IRCC, progress continues to be made to establish this agreement.