Our review and decision
Changes made to the program
Effective October 1, 2025, changes have been made to the Voluntary Disclosures Program to make it easier to apply to the program and understand it. Visit Changes to the Voluntary Disclosures Program for further details.
On this page
Our review
Once we receive your application, we will review it to make sure it meets the necessary conditions of an eligible application.
If we need more information
While we are reviewing your application, a CRA employee may need to contact you for more information or documents. If we do not receive the requested information or documents within a reasonable timeframe, we may deny your application as incomplete.
Audit and investigation
An application is not voluntary if an audit or investigation has been initiated against the taxpayer or a related taxpayer in respect of the information being disclosed. In the VDP context, audits or investigations are not limited to those conducted by the CRA. They can also be conducted by a law enforcement agency, securities commission, or other federally or provincially regulated authority.
Types of application
Unprompted application
The CRA will normally consider an unprompted application for general relief. This situation usually occurs when:
- an application is made when there has been no communication (verbal or written) about an identified compliance issue related to the disclosure
- an application is made following an education letter or notice that offers general guidance and filing information related to a particular topic
Prompted application
The CRA will normally consider a prompted application for partial relief. This situation usually occurs when:
- an application is made following verbal or written communication about an identified compliance issue related to the disclosure, which may include letters or notices (excluding education letters) to the taxpayer or registrant with one or more of the following:
- an identification of a specific error or omission found on the taxpayer’s or registrant’s account
- a deadline to correct an error or omission, where there is an expectation for the taxpayer to file or comply
- an application is made after the CRA has already received information from third-party sources regarding the potential involvement of a specific taxpayer or registrant (or of a related taxpayer/registrant) in tax non-compliance
Relief levels and limits
Depending on the situation, different types of relief may be granted.
General relief
An unprompted application is normally eligible for general relief and will receive 75% relief of the applicable interest and 100% relief of the applicable penalties.
Partial relief
A prompted application is normally eligible for partial relief and will receive 25% relief of the applicable interest and up to 100% relief of the applicable penalties.
Wash transactions relief
Wash transactions are normally eligible for 100% relief of the applicable penalties and interest where the transaction would be eligible for a reduction of penalty and interest under the policy set out in GST/HST Memorandum 16-3-1.
Ten-year limitation period
The CRA provides relief depending on the limitation period for relief of penalties and interest. Under subsection 220(3.1) of the Income Tax Act, the Minister’s ability to grant penalty relief is limited to any penalty that could apply to any tax year that ended within the previous 10 years before the calendar year in which the application is filed. The Minister also has the discretion to cancel interest that accrued during the 10 calendar years preceding the year in which the request for relief is made, regardless of the tax year in which the tax debt arose. For more information, go to Limitation period on exercising discretion and the deadline for requesting relief.
Supplemental relief
If a VDP application is eligible for relief, no matter the level of relief being granted (general, partial, or wash transactions), the CRA will grant the taxpayer or registrant protection from criminal prosecution, and gross negligence penalties will not apply.
Our decision
If the CRA grants you VDP relief
We will send you a letter with the following information:
- which type of application you submitted (unprompted or prompted)
- which level of relief is granted (general, partial, or wash transactions)
- which tax years or reporting periods are eligible for relief
If the CRA does not grant you VDP relief
We will send you a letter giving you the reason why relief is not granted.
Disagreeing with our decision
If you disagree with the CRA's decision or believe the minister of national revenue has been unfair or unreasonable, you still have options. You can:
- request a second administrative review, or
- apply to the Federal Court for a judicial review of the Minister’s decision.
Generally, taxpayers and registrants should ask for a second administrative review from the CRA before applying for a judicial review with the Federal Court.
Asking for a second administrative review
To request a second review, send your written request to the Assistant Director of the Shawinigan National Verification and Collections Centre.
Asking for a judicial review
To request a judicial review, you must send a completed Form 301, Notice of Application, with the appropriate filing fee, to the registrar of the Federal Court.
For more details, refer to:
- paragraphs 40 and 41 of Information Circular IC00-1R7
- paragraphs 38 and 39 of GST/HST Memorandum 16-5-1
Objection rights
There is no right of objection for a decision made under the VDP, because legislation does not give a person the right to dispute a discretionary decision about providing VDP relief. Under subsection 165(1.2) of the Income Tax Act, a taxpayer is prohibited from filing an objection to dispute the assessment of penalties and interest made under subsection 220(3.1).
Relief alternatives
If you do not qualify under the VDP, you may be eligible:
- under the taxpayer relief provisions
- to request a remission review