What timing is worth
Unprompted, prompted, or too late
For applications received on or after October 1, 2025, the old General and Limited streams are gone. There are now two live positions and one closed door.
Position 01
Unprompted
You come forward with no CRA contact on the issue. A general education or reminder letter no longer burns this.
No criminal referral. Gross negligence penalties waived.
Position 02
Prompted
The CRA named a specific error, set a deadline, or received third-party information about you — but has not opened an audit.
Still no criminal referral. A letter is no longer the end of the road.
Door closed
Under audit
Once an audit or investigation into the issue has begun — for you or a related taxpayer — the VDP is off the table for that matter.
Taxpayer relief and objections may remain. Different process, different odds.
Relief levels reflect Information Circular IC00-1R7, effective October 1, 2025. Actual relief is discretionary and subject to the ten-year limit under subsection 220(3.1).
01
Voluntary
Filed before an audit or investigation into the issue has been initiated against you or a related taxpayer.
02
Complete
Every error, every affected year, with documentation. This is where most self-filed disclosures die.
03
One year past due
The return, form, or election must be at least a year past its filing deadline.
04
Tax at risk
There has to be a penalty or interest exposure. A disclosure that only produces a refund is not a VDP matter.
05
Payment or a plan
The estimated tax is paid, or a payment arrangement is in place. Form RC199 was redesigned in October 2025.
The window
The cost of waiting is not linear
Interest compounds daily and the ten-year relief limit keeps moving, so the earliest years fall out of reach whether or not anyone is looking. Then one event — an audit letter naming the issue — removes the option entirely.
Unprompted, full relief available
Anonymous pre-disclosure discussion available before you commit or identify yourself.
Prompted — interest relief drops to 25%
A specific error identified, a correction deadline, or third-party data naming you.
VDP unavailable on that issue
Gross negligence penalties and prosecution exposure are back on the table.
Beyond the relief limit
Penalties and interest older than the statutory window cannot be cancelled at all.
Before you file anything
A disclosure that is incomplete, or filed a week after an audit opens, is not a smaller version of a valid one. It is invalid — and you have handed the CRA the file.
Talk it through firstThe worst version of this conversation is the one that starts after the audit letter arrives. There is a much better version, and it is available right now.
Find out where you stand before the CRA decides for you
You work directly with Robert Occhiuto, CPA, CA — In-Depth Tax certified, 20+ years in public accounting. The first conversation is free.