Directive on Conflict of Interest

Version: 6.0

Version date: February 9, 2026

PDF version

Upon request, this directive is available in multiple formats for individuals with a visual impairment (email MULMEDFORMG@cra-arc.gc.ca).

On this page

1. Effective date

2. Application

3. Related corporate policy instruments

4. Overview

5. Objective and outcomes

5.1 Objective

5.2 Outcomes

6. Requirements

6.1 Affirmation process

6.2 Disclosure requirements

6.3 Assessment of confidential disclosures

6.4 Determination

6.5 Recourse

6.6 Privacy and Confidentiality

7. Roles and responsibilities

7.1 Board of Management

7.2 Commissioner

7.3 Assistant Commissioner (AC), Human Resources Branch (HRB) and Chief Human Resources Officer

7.4 Director General, Workplace Relations and Compensation Directorate (WRCD)

7.5 Director of Values, Integrity and Workplace Policies and Programs Division (VIWPPD)

7.6 Values and Ethics Office (VEO)

7.7 Assistant Commissioners (branches and regions)

7.8 Delegated managers for conflict of interest

7.9 All executives, managers, and team leaders

7.10 Labour Relations Advisors – Regional Workplace Relations Centres of expertise

7.11 Executive Labour Relations Advisors - Executive Workplace Relations Section

7.12 Senior Officer for Post-Employment (SOPE)

7.13 Employees

8. References

9. Enquiries

Questions about the application of this directive or about specific conflict of interest situations should be sent through the HR Service Centre.

10. Version history

10. Version history
Version number Revision Type of revision Area responsible Approved by: Approval date Effective date
6.0 Full revision Cyclical full review HRB

Board of Management

(2025-2026-10)

2025-09-23 2026-02-09
5.0 Full revision Cyclical full review HRB

Board of Management

(2020-2021-23)

2021-01-13 2021-04-01
4.2 Broken links repaired and instrument titles updated as needed Administrative update HRB AC, HRB 2019-04-10 2019-04-29
4.1

Addition of "Commitment" title in section 6.1

Addition of the word cannabis to Appendix C, 1(a)(iv)

Revision HRB AC, HRB 2018-09-18 2018-10-17
4.0 (b)

Minor wording changes throughout

Includes changes made to Version 4.0 (a)

Revision HRB Board of Management
(2018-2019-02)
2018-04-05 2018-04-05
4.0 (a)

Revisions to reflect separation of confidential disclosure form into three:

  • Private interest and outside activities disclosure
  • Gifts and hospitality disclosure
  • Post-employment disclosure

Addition of scenarios to Appendix A to increase awareness.

Revision HRB

Board of Management (2017-2018-31)

Note: Version 4.0 (a) was approved but never published until Version 4.0 (b) in April 2018

2017-12-15 2017-12-15
3.0

Change of approval authority in Section 1.0

Use of standard wording in Section 2.0

Addition of link to Leaving the CRA in 7.3.(c), and References

Revision HRB

Board of Management

(2016-2017-18)

2016-12-16 2016-12-16
2.1

Addition of Lobbying Act to References section, and lobbying restrictions in post-employment

Amended references to executive/cadre from EC to EX.

Former Tools 1-4 changed to Appendices A-D (no change in language).

Addition of the Senior Officer for Post-employment

Changes to gifts threshold

Revision HRB AC, HRB 2016-04-19 2016-05-02
2.0 Human Resources Branch policy simplification: Updated  2014 Directive on Conflict of Interest and Post-employment, incorporating content from the 2001 Gifts, Hospitality and Other Benefits Policy and Guidelines, and converting the 2014 Procedures for assessing and managing confidential disclosures to a Tool for delegated managers Revision HRB AC, HRB 2015-12-17 2015-12-17
1.0 Complete replacement of previous Conflict of Interest Policy, and Conflict of Interest Code and Guidelines New CPI HRB AC, HRB 2014-02-06 2014-03-01

Appendix A – Private interests and outside activities

As a CRA employee, you have a responsibility to uphold the integrity of the organization and maintain public trust. While you may have a variety of private interests and outside activities, it is essential that they do not impair, or appear to impair, your ability to perform your duties objectively and impartially.

To manage conflicts of interest, you must disclose particular private interests, outside activities, and any planned contracts or contractual arrangements with the Government of Canada, including the CRA, as outlined in this Appendix using the appropriate confidential disclosure form and provide clear and sufficient information to allow your delegated manager to make an informed determination.

Part 1 - Private interests, assets, liabilities and relationships

  1. Disclosure requirements

    Employees must disclose all of the following private interests, assets, liabilities, and relationships:

    1. Publicly traded securities of corporations and foreign government including but not limited to:
      • Stocks, shares, bonds/debentures, trust units, Exchange Traded Funds (ETF) or other self-directed or self-administered financial instruments
      • Shares, units or similar equity interests and investment funds that are concentrated in specific businesses or industries
      • Publicly traded securities, such as those described above, held in self- directed or self-administered Registered Retirement Savings Plans- (RRSP), Registered Education Savings Plans (RESP), Tax-Free Savings Accounts (TFSA), First Home Savings Accounts, or similar tax saving vehicles established for your own benefit or for the benefit of others
      • Securities held and traded through investment clubs which are self-directed or self-administered
    2. Cryptocurrencies, crypto-assets, commodities, futures, and foreign currencies held or traded for speculative purposes
    3. Interests in partnerships, proprietorships, joint ventures, private companies, family businesses, or commercially operated farm businesses (including those that own or control shares of public companies or that do business with the GC, including the CRA.
    4. Real property that is not for your private use (for example: investment property, rental property, including a property rented to a friend or family member)
    5. Assets placed in trust or resulting from an estate of which you are a beneficiary
    6. Secured or unsecured loans granted to people other than your immediate family
    7. Direct and contingent liabilities in respect of any of the private interests described in this section
    8. Any personal relationship in the workplace, where you directly or indirectly influence decisions related to hiring, promoting, evaluating, or making other career-related decisions for that individual
    9. Any other assets, liabilities or relationships that could give rise to a real, apparent, or potential conflict of interest due to the particular nature of your duties or the non-public information you have access to, which would not otherwise have to be disclosed
  2. Exceptions from Disclosure

    Employees are not required to disclose the following private interests, assets, liabilities, and relationships:

    1. Canada Savings Bonds and other similar investments in securities of fixed value issued or guaranteed by any level of government in Canada or agencies of those governments
    2. Registered Retirement Savings Plans (RRSP), Registered Education Savings Plans (RESP), and Tax-Free Savings Accounts (TFSA), that are not self-administered or self-directed, and where you are not making investment decisions on individual or personal investments
    3. Exchange Traded Funds or Investments in open-ended mutual funds
    4. Guaranteed investment certificates (GICs) and similar financial instruments
    5. Residences, recreational properties, and farms for your private use that are not used to generate income (and mortgages on same)
    6. Household goods, personal effects, art, antiques, and collectibles
    7. Annuities, life insurance policies and pension rights
    8. Money owed by a previous employer, client, or partnership, personal loans receivable from members of your immediate family, and small personal loans receivable from other persons
    9. Any personal relationship in the workplace, where you have no direct or indirect influence on decisions related to hiring, promoting, evaluating, or making other career-related decisions for that individual

Part 2 - Outside activities and employment

  1. Disclosure requirement

    Employees must disclose any outside activities, employment, or volunteer work that involve:

    1. Accounting, bookkeeping, procurement, finance, and tax-related activities, including but not limited to:
      • Legal or consulting services related to taxation, audits, or financial compliance
      • Roles with access to or influence over financial records, audits, or regulatory decisions
      • Financial planning, advisory services, or sales
      • Mortgage brokering
      • Life insurance advice and sales
      • Issuing official donation receipts
    2. Real estate sales or appraisals
    3. Membership on a board of directors
    4. International assignments or opportunities
    5. Teaching, publishing, or public speaking, including:
      • Academic reports
      • Attending conferences/seminars as a panellist, speaker, or moderator
    6. Social Media or content creation activities involving topics related to government policies or CRA duties. (See Directive on Social Media Account Creation and Management)
    7. Serving as an active representative (for example: executor, administrator, power of attorney, trustee, guardian, immigration consultant, etc.) of a third party’s property, immigration affairs, financial matters, or in matters against the CRA
    8. Non-candidacy political activities as defined by the Public Service Employment Act (See Participating in political activities)
    9. Any other outside activities that could give rise to a real, apparent, or potential conflict of interest due to:
      • a connection with the legislation administered by the CRA.
      • a link to the nature of your CRA duties
      • your access to non-public or confidential information
  2. Exceptions from Disclosure

    Employees are not required to disclose the following outside activities, whether paid or unpaid:

    1. Ad hoc or ongoing outside activities where you do not hold a position of influence in the activity and which are not listed in Part 2.a. Disclosure requirement section
    2. Preparation and filing of CRA documents on behalf of others, provided that they meet the following:
      • They neither seek nor receive any compensation, gift, or favour
      • They do not provide any information or service beyond what a person would normally receive from the CRA
      • The documents being prepared are not related to a business

Part 3 - Contracts or Contractual arrangements with the GC, including the CRA

  1. Disclosure and Approval Requirements

    Employees must disclose and obtain prior approval before bidding on or entering into any contracts or contractual arrangements, through their private interests or outside activities, that result in direct or indirect benefits or income from the GC, including the CRA.

    This requirement applies when employees:

    1. Have a financial interest in a business that contracts with the GC, including the CRA, where they are directly or indirectly involved in the contract or have decision-making authority over it
    2. Serve on a board of directors of a business contacting with the GC, including the CRA, where they are directly or indirectly involved in the contract or have decision-making authority over it
    3. Are employed by or volunteer for a business contracting with the GC, including the CRA, where they are directly or indirectly involved in the contract or are performing the work described in the contract
  2. Exceptions from Disclosure

    Employees are not required to disclose and obtain prior approval before bidding on or entering into any contracts or contractual arrangements, through their private interests or outside activities, when they:

    1. Have passive income from investments in, or serve on a board of directors of, a business contracting with the GC, including the CRA, where they are not involved in the contract or have decision-making authority over it
    2. Are employed by or volunteer for a business that contracts with the GC, including the CRA, where they are not involved in the contract or performing the work described in the contract

Appendix B – Gifts and other advantages

As a tax administration, the CRA is committed to the highest standards of integrity, transparency, and ethical conduct in all business dealings. The acceptance of gifts and other advantages can create real or perceived conflicts of interest, potentially influencing decision-making or undermining public trust in our organization.

To protect CRA’s objectivity, impartiality, and integrity - and to prevent any perception of obligation to a donor - employees are expected to provide fair and impartial service to all taxpayers, benefit recipients, and any individual or organization interacting with the CRA.

Acceptable Gifts and Other Advantages

Infrequent incidental gifts and other advantages with a commercial value of less than $25.00 are permissible only when all of the following conditions are met:

Prohibited Gifts and Other Advantages

Employees must never solicit or accept gifts or advantages in the course of their duties from individuals or organizations that do business with, or have dealings with, the CRA. Prohibited items include, but are not limited to:

Disclosure requirements

Prohibited gifts and other advantages must be declined and must never be solicited. Declined prohibited gifts and advantages do not need to be disclosed.

However, in rare situations where declining a prohibited gift or advantage is not feasible due to cultural norms, Indigenous traditions, or established business protocols, employees may retain the gift but must disclose it using a confidential disclosure form. Only the delegated manager has the authority to determine the appropriate course of action.

Fundraising

When fundraising in the workplace, employees are prohibited from soliciting gifts, hospitality, benefits, or financial contributions - including donations, prizes, or other transfers of economic value from external organizations or individuals.

However, employees may personally donate items such as goods, merchandise, or non-work-related services. For further guidance, see the Employee fundraising information tool.

Appendix C – Post-employment obligations

CRA employees remain responsible for avoiding any real, apparent, or potential conflict of interest between their most recent CRA duties and any future employment or self-employment outside of the CRA and the Government of Canada (GC). Even after leaving their CRA position, they must not engage in activities that could undermine public confidence or the integrity of the CRA.

To manage conflicts of interest, departing and former employees are subject to ongoing obligations. Additionally, for a period of one year following their departure, any acceptance of employment that might give rise to real, apparent, or potential conflict of interest must be disclosed.

Part 1 - Before leaving the CRA

Post-employment Disclosure Requirements

All employees are required to disclose the acceptance of future employment and activities outside of the CRA and the GC that might give rise to a real, apparent or potential conflict of interest in relation to their most recent CRA duties. Employees must provide sufficient information about the future employment and activities using the Post-employment disclosure form.

Employees in the Executive (EX) group (including a temporary assignment in the EX group) are also required to disclose firm offers of employment outside the CRA and the GC.

Part 2 - After Leaving the CRA

  1. Ongoing post-employment obligations

    Former employees must comply with the following obligations, which have no time limit.

    Confidentiality and Protection of Information

    Former employees have signed an Oath or Affirmation committing to perform their duties as assigned and to refrain from disclosing any non-public information obtained during their employment. Unauthorized disclosure or use of taxpayer information by a current or former employee may constitute a breach of Section 241 of the Income Tax Act, Section 295 of the Excise Tax Act, or Section 211 of the Excise Act, 2001. Such breaches are subject to significant legal penalties.

    Being a representative

    Former employees are prohibited from representing or acting on behalf of persons or entities in any ongoing proceedings, transactions, negotiations, or cases to which the CRA is a party, where they:

    • acted for or advised the CRA on the matter; or
    • supervised employees who acted for or advised the CRA on the matter.

    Communicating with the CRA

    Former employees must not contact current CRA employees (including colleagues, or managers they worked with while employed at the CRA) on any business related to the CRA, in any manner that could be perceived as seeking preferential treatment or privileged access. Business-related contact with the CRA must be through normal channels and service points available to the public (for example: My Account, My Business Account, etc.).

    Contracting and Lobbying with the CRA and the Government of Canada

    Former employees may be subject to additional conditions when entering into contracts or contractual arrangements with the GC, including the CRA. For more information, refer to the Directive on the Management of Procurement and the Directive on Contracting with Former Public Servants.

    Former EX-04 and EX-05 employees may be subject to a five (5) year restriction on lobbying the GC. For more information, see the Lobbying Act.

  2. Limitation period

    Former employees are subject to a one (1) year limitation period after leaving their employment at the CRA.

    During this period, former employees must:

    1. disclose in writing to the Senior Officer for Post-employment (SOPE) any acceptance of employment and activities that give rise to a real, apparent, or potential conflict of interest in relation to their most recent CRA duties and responsibilities; and
    2. not engage in the following activities:
      • accept employment with an entity outside of the Public Service of Canada with which they had official dealings during the one (1) year immediately prior to leaving the CRA, whether the official dealings were direct or through their subordinates
      • accept appointment to a board of directors of a private entity with which they had official dealings during the one (1) year immediately prior to leaving the CRA, whether the official dealings were direct or through their subordinates
      • make representations to the CRA on behalf of persons or entities with which they had official dealings during the one (1) year immediately prior to leaving the CRA, whether the official dealings were direct, or through their subordinates

    Request for reduction or waiver of limitation period

    In exceptional circumstances and where it will not compromise the public interest, the SOPE, in consultation with the delegated manager, may consider reducing or waiving the one (1) year limitation period.

    Former employees must submit a written request to the SOPE via email at NATSOPEG@cra-arc.gc.ca.

Part 3 - Failure to comply

Failure to comply with the post-employment provisions of this directive may result in actions taken by the CRA, such as filing a complaint with the new employer or the professional association. Additional measures may include referral to a law enforcement agency or other legal action.

Page details

2026-02-09