Voluntary Disclosures Program (Applications Received On or After October 1, 2025)
GST/HST Memorandum 16-5-1
September 2025
This memorandum provides information to help applicants understand how the Voluntary Disclosures Program (VDP) works, including who can apply, how to apply, what relief can be expected, and how the Canada Revenue Agency evaluates an application. This memorandum applies to VDP applications received on or after October 1, 2025. Applications received prior to October 1, 2025, will be considered for the VDP relief outlined in GST/HST Memorandum 16-5, Voluntary Disclosures Program.
This memorandum applies to disclosures relating to the GST/HST and excise taxes under the Excise Tax Act, excise duties under the Excise Act, 2001, the fuel charge under Part I of the Greenhouse Gas Pollution Pricing Act, the luxury tax under the Select Luxury Items Tax Act, the underused housing tax under the Underused Housing Tax Act, the digital services tax under the Digital Services Tax Act, tax under the Global Minimum Tax Act, and charges under the Air Travellers Security Charge Act and the Softwood Lumber Products Export Charge Act, 2006.
For purposes of this memorandum, the above mentioned acts will be referred to as the applicable Acts.
For information regarding the VDP as it applies to income tax disclosures, refer to Income Tax Information Circular IC00-1R7, Voluntary Disclosures Program.
Table of Contents
What is the Voluntary Disclosures Program
1. The Voluntary Disclosures Program (VDP) is an opportunity for a person to inform the Canada Revenue Agency (CRA) about and correct errors or omissions in their tax obligations. If relief is provided by the CRA under the VDP, a person may receive some penalty and interest relief, and will not be referred for criminal prosecution. Any taxes owing will still have to be paid by the person in full.
2. The VDP aims to provide relief that is fair and is not intended to reward non-compliance. In other words, a person that follows the rules should not be worse off economically than a person who uses the VDP. The VDP is not intended to serve as a vehicle for persons to intentionally avoid their legal obligations under legislation administered by the CRA.
How is the Voluntary Disclosures Program applied
3. The VDP addressed in this memorandum applies to disclosures relating to the applicable Acts administered by the Minister of National Revenue (Minister), and the Minister's discretionary authority to provide relief under the following provisions:
- sections 88, 281.1, and 284 and subsection 284.1(3) of the Excise Tax Act (ETA)
- section 4 of the Credit for Provincial Relief (HST) Regulations
- sections 173 and 255.1 of the Excise Act, 2001
- sections 100 and 125 of the Greenhouse Gas Pollution Pricing Act
- sections 85 and 120 of the Select Luxury Items Tax Act
- sections 26 and 48 and subsection 33(7) of the Underused Housing Tax Act
- subsections 72(1) and 105(1) of the Global Minimum Tax Act
- sections 57 and 90 of the Digital Services Tax Act
- sections 30 and 55 of the Air Travellers Security Charge Act
- section 37 of the Softwood Lumber Products Export Charge Act, 2006
The Minister's discretionary authority is delegated to designated CRA officials.
4. The information in this memorandum is intended to be used as a guide only. It is not exhaustive, and is not meant to restrict the spirit or intent of the applicable Act, or to unduly limit the CRA's discretion with respect to the VDP. The CRA is not required to grant relief for all applications made to the VDP. Each request will be reviewed and decided on its own merits. In exercising discretion, the CRA is guided by principles of procedural fairness, which require decisions to be made in good faith, in a manner that promotes the objects of the applicable Acts.
Types of relief available
5. If the VDP relief is granted, there are three main benefits a person may receive:
- penalty relief
- interest relief
- no referral for criminal prosecution for the issue(s) disclosed
6. The VDP also provides relief for applications involving GST/HST wash transactions that are eligible for a reduction of penalty and interest under the policy set out in GST/HST Memorandum 16-3-1, Reduction of Penalty and Interest in Wash Transaction Situations.
7. The exact amount and/or type of relief will vary depending on the nature of the disclosure.
Application process
Who can apply
8. Any person can apply to the VDP to disclose errors or omissions in their tax obligations. However, the following conditions must be met to qualify for relief:
- The application is eligible, which means that all of the following conditions are met:
- the application is voluntary (go to Determination of voluntary)
- the application includes information that relates to a reporting period that is at least one period past the due date for filing
- the application includes an error or omission with applicable interest charges, penalties, or both
- All supporting documents are included, which means that:
- an applicant provides all relevant information for all required reporting periods and responds comprehensively and promptly to all CRA requests for information (go to What to include)
- Payment or a request for a payment arrangement is made for the estimated tax owing, if it applies
9. Under certain circumstances, a person will not be eligible for relief under the VDP. Examples of such circumstances include the following:
- the application relates to an increase in the amount of input tax credits, other credit adjustments, or rebates without any corresponding increase in tax liability in the application period
- a person is seeking relief on existing penalties and/or interest, that have already been assessed
- the application seeks to make or alter an election under an act administered by the CRA
- there is an insolvency event for the years involved in the disclosure
10. Applicants must remain compliant after being granted relief under the VDP. The CRA may consider a subsequent application from the same person if the circumstances are beyond the person's control or related to a different matter than a previous application.
Pre-disclosure discussion
11. A person that is unsure if they want to proceed with a VDP application is given an opportunity to participate in preliminary discussions about their situation on an anonymous basis to gain:
- insight into the VDP process
- a better understanding of the risks involved in remaining non-compliant
- a better understanding of the relief available under the VDP
12. Such discussions with a CRA official are for the benefit of the person; they are informal and non-binding.
13. For more information, go to Need more information.
Determination of voluntary
14. The VDP application must be voluntary in order to be granted relief.
15. An application is not voluntary if an audit or investigation has been initiated against the person or a related person 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.
16. Voluntary applications are eligible for general (unprompted) or partial (prompted) relief. Refer to Levels of relief. Eligible wash transactions will also be considered for the applicable relief.
Unprompted application
17. An application is generally considered unprompted in the following situations:
- 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
18. An application is generally considered prompted in the following situations:
- 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 person with one or more of the following:
- an identification of a specific error or omission found on the person's account
- a deadline to correct an error or omission, where there is an expectation for the person 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 person (or of a related person) in tax non-compliance
Levels of relief
19. Based on the Determination of voluntary, the CRA will evaluate whether the taxpayer qualifies for general, partial, or wash transactions relief, if it applies:
- Unprompted applications are normally eligible for general relief and will receive 75% relief of the applicable interest and 100% relief of the applicable penalties.
- Prompted applications are 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 within a VDP application will receive 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.
20. If a VDP application is eligible for relief, protection from prosecution will be granted, and gross negligence penalties will not apply on the information disclosed.
21. Relief is provided in line with the limitation period for relief of penalties and interest found in the applicable Acts (go to paragraph 3 of this memorandum for a list of the various legislative provisions). For more information, go to Limitation period on exercising discretion and the deadline for requesting relief.
How to apply
What to include
22. To apply to the VDP, applicants must complete Form RC199, Voluntary Disclosures Program (VDP) Application.
23. An applicant may choose to use an authorized representative to submit the application on its behalf. The CRA can only discuss and provide a person's information to the person or their authorized representative. Go to Authorize a representative: Overview for information on how to authorize a representative.
24. The applicant must disclose all known errors and omissions in its tax obligations, including any arm's length and non-arm's length transactions or circumstances relating to the errors and omissions.
25. Supporting documentation (for example, returns, forms, statements, schedules) needed to correct the non-compliance for the most recent four (4) years must be included with the application.
26. A reporting period within the above timeframe with no errors or omissions does not need to be included with the application. Additional documentation for reporting periods beyond the above timeframe may be requested by the CRA at its discretion.
27. CRA officials may request additional documents, records, books of account, as well as other additional specific documentation relevant to the disclosure. In cases where books and records do not exist, applicants should make all reasonable efforts to provide estimates.
28. If an applicant received assistance or advice from an individual (including a tax professional or promoter) for the subject matter of the disclosure, the name of that individual must be included in the application form.
29. An application may be denied if a person fails to provide the required information, including, but not limited to, in the following circumstances:
- the application does not include sufficient information to support the disclosure
- a person does not comply with requests for additional information from the CRA within the timeframes given, or provides insufficient detail to allow the facts of the case to be verified
- the CRA learns of other issues of non-compliance that were not originally included in the disclosure
Payment
30. For an application to be granted relief, payment or a request for a payment arrangement of the estimated taxes owing must be made, if it applies. The CRA's approval of a payment arrangement is not guaranteed, and all requests will be reviewed by CRA collections officials.
CRA decision
31. Once the CRA receives and acknowledges receipt of a VDP application, an effective date of disclosure (EDD) will be provided. If the application is ultimately deemed eligible for relief, the applicable relief will be granted to the person up to the EDD.
32. A decision will be made as to whether the person qualifies for relief under the VDP. To qualify for relief, all of the following conditions must be met:
- the person is eligible to apply at the time of application (go to Who can apply)
- the person provides all relevant supporting documentation (go to What to include)
- the person includes a payment or makes a request for a payment arrangement for the estimated tax owing, if it applies
33. Once the application review is complete, the person will be notified in writing of the CRA's decision to provide relief or not.
34. Given the complexity and technical nature of certain disclosures, the VDP may request technical assistance from specialty areas within the CRA where appropriate.
35. The CRA reserves the right to audit or verify any information provided in a VDP application, whether relief is granted under the VDP or not. The VDP conducts limited scope reviews and determines eligibility for penalty and interest relief only. Subject to applicable statute limitation rules, additional assessments of tax may arise for any reporting period following a review by another area of the CRA. In addition, if the CRA finds there is fraud or any misrepresentation due to neglect, carelessness, or willful default, an assessment may be issued at any time for any reporting period to which the fraud or misrepresentation relates, not just those periods included in the VDP application.
Right of redress for applicants
Second administrative review
36. If a person believes that the CRA has not exercised discretion in a fair and reasonable manner, the person may request in writing that the Assistant Director of the Shawinigan National Verification and Collections Centre review and reconsider the original decision through a second administrative review. The person may make additional representations for the CRA to consider.
37. The Assistant Director may designate a new officer, not involved in the previous review and decision, to conduct the second administrative review on the Assistant Director's behalf.
Judicial review
38. A person should request a second administrative review from the CRA before filing an application for a judicial review with the Federal Court.
39. Where a person believes the CRA has not exercised discretion in a fair and reasonable manner, the person may file an application to the Federal Court for a judicial review of the CRA's discretionary decision, under section 18.1 of the Federal Courts Act, within 30 days from the date the CRA sent the notification of the decision to a person. For more information, go to Judicial review.
Objection rights
40. There is no right of objection for a decision made under the VDP as legislation does not give a person the right to dispute a discretionary decision about providing VDP relief. However, an applicant has the option to request relief of interest and any penalties payable that was not granted under the VDP, but may be in line with the taxpayer relief provisions in other legislation as described in Income Tax Information Circular IC07-1R1, Taxpayer Relief Provisions.
Where to submit an application
41. The completed VDP application can be submitted either:
- electronically using the Submit documents online service in the My Account, My Business Account, or Represent a Client portal, which can be accessed by going to Sign in to your CRA account
- by mail or fax:
Voluntary Disclosures Program
Shawinigan National Verification and Collections Centre
4695 Shawinigan-Sud Boulevard
Shawinigan QC G9P 5H9
Fax: 1-888-452-8994
Need more information
42. For more information on the VDP, go to Voluntary Disclosures Program (VDP).
43. For questions about the VDP, or to request a Pre-disclosure discussion, you can contact the following CRA general enquiry lines:
- for individuals, call 1-800-959-8281
- for businesses, call 1-800-959-5525
- for all others, go to Contact the Canada Revenue Agency (CRA)
Further Information
All technical information and publications related to the Acts administered by the Minister of National Revenue are available at Technical tax information.
For Quebec enquiries, call Revenu Québec at 1‑800‑567‑4692 or go to revenuquebec.ca.