- The CRA's acknowledgement letter sets an effective date of disclosure, and relief runs up to that date if you qualify.
- Relief applies to penalties and interest, so the tax itself must still be paid.
- Protection from prosecution covers only the information you disclosed, and the CRA can still audit it.
You filed your Voluntary Disclosures Program (VDP) application, waited, and now a letter has arrived. It is natural to read it with relief, then wonder what actually happens next and whether anything more is expected of you.
This article walks through the stages after the CRA responds, how to read the decision, what still has to be paid, and what staying onside looks like. Your own letter and your own tax years control the details, so a lawyer or accountant should review them with you.
This article covers Canadian federal tax law, which applies in every province.
Acknowledgement is not the same as the decision
After the CRA receives an application, it sends an acknowledgement letter that shows the effective date of disclosure (EDD). Relief runs up to the EDD if you qualify.
Which rules apply depends on when the CRA received your application. The current circular, IC00-1R7, applies to applications received on or after October 1, 2025, and earlier applications fall under IC00-1R6.
The CRA then reviews the application for eligibility, may ask for more information, and finally issues a written decision. The CRA does not publish a processing time, so you cannot count on a particular wait.
If the CRA asks for documents, answer within a reasonable timeframe. An application can be denied as incomplete if requested information is not provided in time.
Reading the decision letter
The decision letter states the application type (unprompted or prompted), the relief level and the eligible tax years. If relief is denied, it gives the reason.
| Application type | Usual interest relief | Usual penalty relief |
|---|---|---|
| Unprompted | 75% | 100% |
| Prompted | 25% | Up to 100% |
An application is generally unprompted if the CRA had not communicated with you about the compliance issue, or if the only contact was a general education letter. It is generally prompted if it followed CRA communication identifying a specific error or setting a correction deadline, or followed third-party information about non-compliance. A CRA letter about a specific issue does not by itself end eligibility; the CRA treats such an application as prompted if you are not under audit or investigation.
For GST/HST, the relief levels match income tax. GST/HST wash transactions that qualify under Memorandum 16-3-1 can receive 100% relief of penalties and interest, whether the application is unprompted or prompted.
Check that the years, amounts and type match what you expected. If something looks wrong, you can use the CRA's callback form to ask about a decision letter.
Payment: the tax is still owed
VDP relief covers penalties and interest, not the tax itself. Tax owing must be paid.
Payment of the estimated tax owing, or a request for a payment arrangement, is a condition of a valid application. Approval of a payment arrangement is not guaranteed, and collections officials review each request.
Compare your decision letter, in particular the application type, relief level and eligible tax years, with what you paid or proposed. Do not assume a gap will sort itself out. If the numbers differ, a tax professional can help you reconcile them.
Protection, audits and reassessment risk
Eligible applicants are protected from prosecution for the disclosed information, and gross negligence penalties do not apply to that information.
That protection has limits. The CRA reserves the right to audit any information in a VDP application whether or not relief is granted, and if fraud or misrepresentation is found, an assessment may cover any year.
- Protection applies to the information you disclosed, not to matters you left out.
- A disclosure that was incomplete or inaccurate can lose its benefit.
- Relief is limited by the ten-calendar-year window in subsection 220(3.1) of the Income Tax Act, so older years may get reduced or no relief.
Staying compliant and what to do next
A taxpayer who received VDP relief must stay compliant. A later application may be considered if the circumstances were beyond their control or concern a different matter. In practice, that means filing and paying on time going forward.
Keep the records behind your application. Income tax applications must include supporting documents for the affected years, which generally cover the most recent six years, or ten years for assets or income located outside Canada. Because the CRA may audit what you disclosed, having those records easy to find is practical.
- Read the decision letter closely and note the type, relief level and years.
- Confirm that payments or the payment arrangement match what the CRA expects.
- Keep copies of your application, supporting records and all CRA letters.
- Diarize future filing and payment dates, including any instalments.
- If you disagree with the decision, ask in writing for a second administrative review by the Assistant Director of the Shawinigan National Verification and Collections Centre.
- Remember that there is no right of objection to a VDP decision. Judicial review in the Federal Court generally must be filed within 30 days of the CRA's notification and follows the second review.
Frequently asked questions
Does acceptance mean I will not be audited?
No. The CRA reserves the right to audit any information in a VDP application whether or not relief is granted. If fraud or misrepresentation is found, an assessment may cover any year.
Do I still have to pay the tax?
Yes. The VDP provides relief on penalties and interest, not on the tax itself. If you cannot pay in full, a payment arrangement can be requested, but approval is not guaranteed.
Can I object if I disagree with the decision?
There is no right of objection to a VDP decision. You can ask in writing for a second administrative review, and judicial review in the Federal Court follows that review.
How long until I hear back?
The CRA does not publish a processing time for VDP applications. You can use its callback form to check the status of an application.
Sources
- CRA – IC00-1R7 Voluntary Disclosures Program — canada.ca
- CRA – The Voluntary Disclosures Program: Your second chance to set things right (June 15, 2026) — canada.ca
- Income Tax Act, s. 220(3.1) — Justice Laws (federal)
- CRA – How to apply (VDP) — canada.ca
- CRA – Our review and decision (VDP) — canada.ca
- CRA – GST/HST Memorandum 16-5-1 ¶19 — canada.ca
Links go to official government, court and regulator pages. The law changes — confirm you are reading the current version.
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