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How to Leverage the New CRA Voluntary Disclosures Program (VDP) Changes

Recent changes to Canada’s Voluntary Disclosures Program make retroactive compliance simpler — here’s how to use the updated relief tiers and eligibility to your advantage.

By NomadicTax Research Team · 5-8 min read

What’s Changed as of October 1, 2025

The Canada Revenue Agency (CRA) updated the Voluntary Disclosures Program (VDP) to make it more accessible and fair. Key changes include a simplified application form, expanded eligibility, and new relief tiers, drawing clear lines between unprompted and prompted disclosures. (canada.ca)

Eligibility: Who Can Participate?

  • Individuals, corporations, trusts, partnerships, and GST/HST registrants etc. are eligible now, provided certain conditions are met. (canada.ca)
  • Excluded: those currently under audit or investigation, or with egregious or intentional non-compliance. (canada.ca)

Relief Tiers: Unprompted vs Prompted Disclosures

Type of ApplicationInterest ReliefPenalty Relief
Unprompted (no prior communication from CRA)75% interest relief100% penalty relief (canada.ca)
Prompted (CRA raised an issue)25% interest reliefUp to 100% penalty relief (canada.ca)

Timeframes & Documentation Requirements

  • Canadian-sourced income or assets: most recent 6 years. (canada.ca)
  • Foreign-sourced income/assets: most recent 10 years. (canada.ca)
  • GST/HST-related periods: most recent 4 years under the updated memorandum. (canada.ca)

Practical Steps to Apply Properly

  1. Decide which tier applies: Were you prompted by CRA or not?
  2. Gather all necessary documents for the required years (6 or 10 years).
  3. Fill out Form RC199, making sure to include full details about the errors or omissions. (canada.ca)
  4. Include estimated tax owing or request a payment arrangement. (canada.ca)
  5. Submit via CRA’s “Submit documents online” portal. Mail or fax in exceptional cases. (canada.ca)

Example Scenario

Suppose Maria, a self-employed consultant, discovers she didn't report some consulting income for two years (Canadian-sourced). She received an educational letter from the CRA, alerting her to possible issues.

  • Because she was prompted, she applies under the prompted relief tier, so she’d be eligible for 25% interest relief and up to 100% penalty relief, assuming she meets documentation requirements.
  • She includes 6 years of Canadian-sourced income details (even though only two years have omissions) and any foreign income over the past 10 years (if applicable).
  • She submits Form RC199, includes the owed taxes, pays or requests payment arrangement, and labels her application properly.

Actionable Advice

  • Don't wait until an audit — unprompted applications provide much better relief.
  • Keep excellent financial records, especially for foreign income or assets.
  • Involve a tax professional when evaluating eligibility or gathering documentation — mistakes can delay relief.
  • Monitor CRA communications: education letters may trigger eligibility.

Sources

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