Ombudsperson Final Update — 2021–2022 Annual Report
Background
During the 2021–2022 fiscal year, the Office of the Taxpayers’ Ombudsperson received higher than usual volumes of complaints and referred a record number of urgent requests to the CRA for individuals experiencing financial hardship.
Many Canadians contacting us identified service issues when trying to receive COVID-19 benefits from the CRA. These complaints accounted for 40% of what we heard. The most prominent reason was that many felt they needed to wait too long to receive their benefit. Generally, this was because of delays at the CRA in validating eligibility.
The CRA’s contact centres was another large complaint driver. For years, we have heard from Canadians about their dissatisfaction with this service. While most of the issues we heard came from dissatisfaction with the CRA’s main line, the Individual Tax Enquiries Line, we also heard about issues with its other contact centres. Some of the issues Canadians expressed to our Office related to excessive wait times, receiving conflicting or inconsistent information, or calls being prematurely disconnected.
This report also highlighted issues accessing CRA accounts, delays in receiving the Canada Child Benefit (CCB), and concerns relating to the Guaranteed Income Supplement (GIS).
Update
We provided three recommendations in the report. The CRA agreed with all three recommendations, created an action plan and provided updates on its action plan in 2024. However, this action plan did not sufficiently address all our recommendations.
Recommendation 1
The Taxpayers’ Ombudsperson recommended to the Minister and to the Chair of the Board of Management that the CRA look for ways in which a taxpayer can receive a security code the same day it is requested, allowing Canadians to have full access to their CRA Account in a timely manner.
Our analysis of CRA’s action plan
The CRA agreed with this recommendation, recognizing, “the need for taxpayers to have timely access to their online account while ensuring the highest level of security and protection of confidential taxpayer information.” The CRA also stated it was
implementing a new Digital Identity Validation (DIV) solution as an enhancement to the current registration process for CRA’s online services. This enhancement will enable taxpayers to validate their identity through a secure, online service and have immediate access to their personal and/or business information online.
2024 update
The CRA informed us in April 2024 that it has launched a document verification service which “provides a secure method for Canadians to validate their identity in real-time allowing full and immediate access to the CRA sign-in services, without needing a CRA security code.” The CRA has considered this action plan item complete and we agree.
That same month, it also announced that it was making it easier for Canadians to access its digital services with its new identity validation option. With the document verification service, taxpayers can now gain full and immediate access to their CRA account. Canadians can now take a picture of their government-issued photo identification to validate their identity and gain same-day access to their CRA account.
In our statement about the launch of the 2025 tax season released on February 26, 2025, the Taxpayers’ Ombudsperson expressed that he was pleased to report that the CRA has expanded ways for Canadians to validate their identities for its online accounts, including My Account, following a recommendation in our Office’s 2021–2022 annual report.
We are also hoping to see more actions from the CRA to improve its document verification service. Currently, to use this service, a taxpayer must have one of the following identification documents:
- Canadian passport
- Canadian driver's license
- Provincial/Territorial photo ID card
However, Interac’s document verification service appears to have the capability to support other documents, such as permanent resident cards.
We sent a request to the CRA about this limitation and the CRA informed us that an analysis is currently underway to identify additional identification documents (including permanent residency cards) that the CRA will accept as valid identification in a future release. The CRA also indicated that in addition to permanent residency cards, it is currently analyzing additional identification documents for implementation, such as the Indian status card and select international passports. The CRA said it anticipates onboarding new identity documents in the 2025–2026 fiscal year. We look forward to seeing these improvements this fiscal year.
Recommendation 2
The Taxpayers’ Ombudsperson recommended to the Minister and to the Chair of the Board of Management that the CRA find a way to provide in-person same-day identity verification of a taxpayer, for example, through a trusted third party.
Our analysis of CRA’s action plan
The CRA agreed with this recommendation. The CRA indicated it has established new partnerships and was developing new processes for taxpayers to gain same-day access to their online account.
The CRA’s specific actions:
In support of the Pan-Canadian Trust Framework (PCTF), the CRA has established partnerships with the provinces of British Columbia and Alberta to be able to leverage their provincial digital ID’s. […] As additional provinces and Territories establish digital identity programs, the CRA will explore partnerships with them.
On September 24th, 2022, the CRA and Employment and Social Development Canada (ESDC) re-enabled the link between My Account and My Service Canada Account. This link allows users of one secure portal to get the other without having to re-login or revalidate their identity.
However, this link is no longer available as work continues on the OneGC Single-Sign-In solution led by the Canadian Digital Service (CDS).
In March 2024, the CRA launched the new Digital Identity Validation (DIV) solution, known as the Document Verification Service. This service allows taxpayers to validate their identity digitally, providing them with faster, secure, and immediate access to their personal and business information online.
2024 update
The CRA reiterated that establishing partnerships with provinces can allow taxpayers to gain immediate access to the CRA’s sign-in services. The CRA also informed us that the Canadian Digital Service (CDS) has completed the PCTF assessment of the Quebec Digital ID for the GC Sign-in service. The CRA said it was evaluating the options available to integrate with Quebec, either directly or indirectly. Once a direction for integration is chosen, the CRA will have a better estimated timeframe for delivery and completion.
This action plan item is ongoing. We acknowledge the effort the CRA is making to establish partnerships with provinces to allow taxpayers immediate access to the CRA’s sign-in services. We also note that the CRA and ESDC have re-enabled the link between My Account and My Service Canada Account to give users access to one secure portal without having to re-login or revalidate their identity.
However, these actions are limited and do not address our recommendation. The establishment of partnerships is only limited to some provinces and the link between My Account and My Service Canada Account is intended for users of the CRA and Service Canada’s sign-in services and does not take into consideration people who do not use these services. The goal of our recommendation was for the CRA to find a way across the country to provide in-person same-day identity verification of a taxpayer through a trusted third party. This would serve more vulnerable segments of the population who are not able to use the CRA sign-in service.
2025 update
The CRA confirmed that:
In March 2024, [it] launched a new document verification service that significantly enhanced the speed and accessibility of identity verification for taxpayers. This service enables individuals to verify their identity immediately and securely online, without the need to wait for a CRA security code by mail.
The CRA has considered this action plan item complete, and we acknowledge the work it has done to improve its service following our Office’s recommendation. However, as noted in our analysis of the CRA’s 2024 update, the steps taken so far do not address the in‑person component of our recommendation.
Recommendation 3
The Taxpayers’ Ombudsperson recommended to the Minister and to the Chair of the Board of Management that the CRA make it clear to Canadians that when it is administering a benefit that increases an individual’s income that it sufficiently informs applicants that the increase could affect their other income based benefits.
Our analysis of CRA’s action plan
The CRA agreed with this recommendation. The CRA said it
understands the importance of effectively communicating the interaction between COVID-19 benefits and provincial or territorial social assistance program. The CRA accept[ed] this recommendation, and will modify existing communications to ensure language is clear and consistent with that which is used elsewhere by the [CRA].
It added that it will also ensure to take this into account for future communications and detailed concrete steps it has already taken, including:
- The Public Affairs Branch has updated its communications strategy template to include a consideration about benefit interactions and the importance of clear language when communicating interactions to Canadians. This update will help ensure that benefit interactions are taken into account in the planning phase of any future strategies related to COVID-19 measures, and are incorporated into related external-facing products.
- The CRA consulted ESDC (the relevant legislative entity) to update the CRA’s landing page for COVID-19 Benefits in accordance with OTO’s Recommendation 3, which will help ensure users are aware of the interaction between the one-time GIS payment and COVID-19 payments. From October 10 to November 8, 2022, the alert was active, and the link in the ‘Most requested’ area will be there indefinitely. The link goes directly to ESDC’s page “One-time grant for Guaranteed Income Supplement recipients who received pandemic benefits”.
2024 update
The CRA indicated that “[b]eginning in 2020, COVID-19 benefits had a unique impact on income reporting unlike other existing federal benefits and credits.” It stated that,
Now that emergency benefits have been closed, the Agency does not have any other benefits that impact income reporting. In the event that the CRA were to develop or issue a benefit with a similar impact on income reporting, [it] would develop and incorporate key messages into communications products to ensure audiences were made aware that the benefit could be considered a part of their reportable income.
The CRA has considered this action plan item completed and we agree. We are satisfied that our recommendation not only led to a change for COVID-19 benefits, but also led to a change for future benefits with similar impacts on taxpayers’ income reporting. We have therefore concluded that the CRA’s action has addressed our recommendation.
Conclusion
Our recommendations in this annual report led to significant service improvements at the CRA. This demonstrates how our Office can influence change in the lives of Canadians through service improvements.
Many times the CRA makes improvements without our influence and this report was also an opportunity for our Office to highlight some of these efforts.