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ARTICLE · 15 SEPTEMBER 2025

Major Changes To Voluntary Disclosures Program Coming Into Effect October 1, 2025

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On September 10, 2025, the Canada Revenue Agency (the "CRA") announced[1] major changes to its Voluntary Disclosures Program (the "VDP").

CanadaTax
Andrea Arbuthnot
Andrea Arbuthnot
Michael H. Lubetsky
Michael H. Lubetsky
Michael Friedman
Michael Friedman
Steven Sitcoff
Steven Sitcoff
Jamie Wilks
Jamie Wilks
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On September 10, 2025, the Canada Revenue Agency (the "CRA") announced1 major changes to its Voluntary Disclosures Program (the "VDP"). The updated program will relax the requirements for a valid voluntary disclosure and provide greater potential relief from interest and penalties. The terms of the VDP have been shortened to simplify the program and its administrative processes. The shift in policy marks a retreat from the more complex and stringent VDP that was introduced in 2018.

The latest changes were introduced with the release of the new Information Circular IC00-1R7 – Voluntary Disclosures Program2 ("IC00-1R7") and GST/HST Memorandum 16-5-1 Voluntary Disclosures Program3 ("GST/HST Memorandum 16-5-1"). Both documents will apply to voluntary disclosures received on or after October 1, 2025. Voluntary disclosures received prior to October 1, 2025 will be considered under the respective predecessor programs, as set out in Information Circular IC00-1R6,

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The foregoing provides only an overview and does not constitute legal advice. Readers are cautioned against making any decisions based on this material alone. Rather, specific legal advice should be obtained.

© McMillan LLP 2025

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